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2015 (1) TMI 1481 - ITAT HYDERABADRectification u/s 154 - validity of the proceedings under S.154 on the ground that it is time barred and even on merits, the assessee is eligible to weighted deduction - HELD THAT:- Revenue is contesting only the issues concerning the period of limitation for passing an order under S.154; and also with regard to the exceptions provided for filing an appeal even where there was no tax effect, but the issue concerning validity of initiating proceedings u/s 154 on the renewed interpretation of law was conspicuously absent in the grounds of appeal. The order of the CIT(A) with regard to the issue concerning validity of proceedings u/s 154 for the reason that the Assessing Officer having applied his mind at the assessment stage, is not entitled to initiate proceedings u/s 154 based on change of opinion, has attained finality. In such an event of the matter, grounds filed before us, even if a decision has to be rendered, are of academic importance. H We are of the view that the appeals filed by the Revenue deserve to be dismissed on the ground that the issues raised herein are of academic importance, since the order passed u/s 154 has no legs to stand on the limited ground that it is based on change of opinion, and on this aspect of the matter has attained finality.
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