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2021 (9) TMI 96

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....dl.CIT For the Respondent : Shri I. Dinesh, Advocate ORDER PER MAHAVIR SINGH, VICE PRESIDENT: This Miscellaneous Application filed by the Revenue u/s.254(2) of the Income Tax Act, 1961 (hereinafter the 'Act') against the order of ITAT in ITA No.2947/Chny/2018, for assessment year 2010-11, dated 28.02.2020. 2. The grievance of the Revenue pointed out that the Income Tax Act does not provide ti....

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....he Act for passing of order u/s.201(1) & 201(1A) of the Act, but there are numerous judgments of various High Courts and Hon'ble Supreme Court and he referred to the decisions of Hon'ble Supreme Court in the case State of Punjab & Ors. Vs. Bhatinda District Coop. Milk P. Union Ltd., SLP (C) No.5040 of 2007, dated 11.10.2007 and Hon'ble Bombay High Court in the case of DIT (International Taxation) ....

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....;s order in this case does not suffer from any error of law apparent on the face of record or perversity warranting our interference in appellate jurisdiction. 36 We are also shown the judgment of the Calcutta High Court in the case of Bhura Exports Ltd. V. ITO (TDS), [2012] 202 Taxman 88/[2011] 13 taxmann.com 162. With respect and for the reasons indicated by us above we cannot agree with the v....

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....e various provisions of the Income-tax Act has been held to be four years in a number of cases. We see no reason to extend this period any further. Consequently, the question is answer in favour of the assessee and against the Revenue." 4. We have heard rival contentions and perused the case laws. It is noticed that the admitted fact is that the assessment year involved is 2010- 11 and order u/s.....