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2003 (11) TMI 54

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..... ted, did not satisfy the mandatory requirement of section 239 and as such could not be entertained - We have perused section 119 of the Act, it is not possible for us to accept that the statutory provision incorporated under section 239 of the Act, is not amenable to relaxation at the hands of the Board through instructions under section 119 – Hence the claim for refund made by the petitioner coul .....

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..... shall be allowed, unless it is made within the period specified hereunder, namely: (a) where the claim is in respect of income which is assessable for any assessment year commencing on or before the 1st day of April, 1967, four years from the last day of such assessment year; (b) where the claim is in respect of income which is assessable for the assessment year commencing on the 1st day of A .....

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