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2022 (5) TMI 1601 - ITAT CHENNAIRectification of mistake - validity of Revision u/s 263 as barred by limitation u/s.153(5) - order of fresh assessment in pursuance of an order u/s 263 setting aside or cancelling an assessment, may be made at any time before the expiry of 9 months from the end of the financial year - DR submitted that the Tribunal has erred in considering the amended provisions of Sec.153(3) since the new time-line has come into force only w.e.f. 01.06.2016 by Finance Act, 2016. It has been submitted that the order u/s 263 was passed on 19.12.2014. HELD THAT:- We are of the prima-facie opinion that it appears to be a case of wrong application of law which would require our interference u/s 254(2). Accordingly, the order stand recalled. The registry is directed to fix the appeal for fresh hearing before regular bench after intimating both the sides.
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