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TMI Blog2022 (5) TMI 1601X X X X Extracts X X X X X X X X Extracts X X X X ..... the Respondent : None ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. By way of this Miscellaneous Petition, the Revenue seeks recall of Tribunal order passed in ITA No.3039/Chny/2018 on 23.12.2020. The bench, in para-4 of the order, quashed the order passed by Ld. AO on 26.02.2016 which is consequent to revisional order u/s 263. This was by considering the provisions of Sec. 153(3) which pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is on record. It has been submitted as under: - It is humbly submitted that the Hon'ble ITAT, A Bench, Chennai has dismissed the appeal of the Department / Revenue vide order in ITA No, 3039/CHNY/2018 dated 23/12/2020. The Order has been received by the office of the CIT (Judicial), Chennai on 06/01/2021 and it was received by the Office of the PCIT-8, Chennai on 08/01/2021. The Scrutiny R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he necessary action in this regard. It is humbly stated that the limitation for rectification of any mistake u/s 254(2) of the IT Act, 1961 in this case was on 30/06/2021. But there is a delay in filing the Misc Application of 55 days, It is humbly stated that the delay is totally unintentional and due to the Lockdown in the State for Pandemic. During the Complete Lockdown from 10/05/2021 to 07/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... since the new time-line has come into force only w.e.f. 01.06.2016 by Finance Act, 2016. It has been submitted that the order u/s 263 was passed on 19.12.2014. As per the old provisions of 153(2A), the time limit to pass such an order was one year from the end of the financial year in which the order was received by the appropriate authority. Accordingly, the order dated 26.02.2016 was passed wel ..... X X X X Extracts X X X X X X X X Extracts X X X X
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