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2019 (2) TMI 1393 - HC - Income TaxRevision u/s 263 - Petitioner's grievance that the Tribunal remanded the proceedings before the CIT(A), in the present case, the powers are exercised by the Principal Commissioner which is not in consonance with the directions of the Tribunal - Rectification application - HELD THAT:- We request the Tribunal to pass an early order on the application for rectification filed by the department. The same may be disposed of preferably within two months from the date of receipt of copy of this order. The apprehension of the Counsel for the Revenue about limitation can be easily put to rest. Once the Tribunal passes an order on the rectification application of the department and rectifies its concluding portion of the order by remanding the proceedings before the Commissioner instead of CIT(A), the directions would take effect from the date of the order on rectification application. Any reference to limitation for passing revisional order may, therefore, to be from said date. We notice that the order of the Tribunal was passed on 27th November, 2017 but the department claims that the same was served on 14th March, 2018 and the rectification application was filed sometime in July, 2019 which would be within six months from the date of communication. Request the Tribunal to hear the rectification application on merits without raising question of limitation.
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