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2022 (3) TMI 288 - AT - Income TaxRevision u/s 263 - order passed under section 201(1) and 201(1A) is erroneous and prejudicial to the interest of the revenue - HELD THAT:- We find the CIT(A) has considered the facts, circumstances, provisions of law and judicial decisions and dealt on the issue of limitation and allowed the appeal. Now, CIT(TDS) has passed revision order u/sec 263 of the Act setting aside the order passed under section 201(1) and 201(1A) of the Act. But the fact remains that, the assessee has challenged the order before the CIT(A) and the CIT(A) has quashed the order.The Ld.DR submitted that the revenue has not filed the appeal against the CIT(A) order with the Honble Tribunal due to low tax effect. We find the revision order of the CIT-TDS does not subsists as the order under section 201(1) and 201(1A) of the Act is annulled. Accordingly, We dismiss the revision order U/sec 263 of the Act on non-maintainability and allow the grounds of appeal in favour of the assessee.
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