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1986 (12) TMI 92 - ITAT HYDERABAD-BExtract: .......f assessment. Under these circumstances, we do not see how the order of the Commissioner on merits could be said to be unreasonable. 32. Although, we have given a finding in favour of the department on the merits of the case, since we have held that the Commissioner has no jurisdiction to revise the order under section 263, the appeals are allowed.
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