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2004 (6) TMI 290 - AT - Income TaxExtract: .......presumption as pronounced in the abovenoted two authorities and other cases cited by learned Authorised Representative is that order may have been passed after the limitation of time. In these circumstances, we allow the additional ground raised by the assessee and quash the order under s. 263 being time-barred. 6. In the result, appeal is allowed.
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