2012 (5) TMI 759

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..... delay in filing the revision has been sufficiently explained on affidavit filed in support of the delay condonation application. Accordingly, delay is condoned. Delay Condonation Application No. Nil of 2012 is allowed. Office to allot regular number to the revision. Filing of the typed copy of the judgment of the tribunal is exempted. Exemption Application No. 45703 of 2012 is allo .....

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..... ere was no fresh material for exercising power under Section 21 of the Act and that it is a case of change of opinion. The said order of the first appellate authority has been affirmed by the tribunal. The submission of the learned counsel for the department is that as the correct legal position had not been considered in passing the initial assessment order. Therefore, no error has been commit .....

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