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Validity of order passed by PCIT u/s 264 - Non-consideration of submissions of the assessee - Contention...

Validity of order passed by PCIT u/s 264 - Non-consideration of submissions of the assessee - Contention of the respondents that it was time barring matter is not acceptable in view of the fact that the relevant assessment order to be revised was received by the petitioner on 4th February, 2020 and as per the statute, limitation is two years from the date of receipt of such assessment order, so, the time for passing the impugned order was becoming barred on 3rd February, 2022 and in view of this..... .....

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