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2021 (12) TMI 768 - HC - Income TaxValidity of Revision order passed u/s 263 by CIT - period of limitation - ITAT to declare the impugned revision assessment order of the Assessing Officer as non-est and is allowing the appeal of assessee against order u/s 263 in technical ground - MAT credit allowability u/s 115JAA - HELD THAT:- As decided in M/S. APEEJAY SHIPPING LIMITED [2021 (12) TMI 262 - CALCUTTA HIGH COURT] the order passed by the CIT u/s 263(2) is hopelessly barred by limitation. The Tribunal rightly held that the period of limitation has to be reckoned from the date of the order passed by the AO under Section 143(3) read with Section 263 and not from the date of the order passed by the AO under Section 143(3) read with Section 263 and 251. Thus, we find that the Tribunal rightly allowed by the appeal filed by the assessee.
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