828/CBDT.

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..... ciple and/or substantial revenue got barred by limitation. It has further been observed that in taking remedial proceedings, action under section 154 of the IT Act is resorted to in a routine fashion and such action frequently been struck down by appellate authorities on the ground that the issue involved was capable of a second view. This has left the Department with no further remedy to retrieve .....

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..... ioners issue similar instructions to the ITOs within the said period of a month. Further, the choice of such remedial action whether under section 154 or 147 or section 263, should be carefully considered so that the interest of revenue is well protected and the chances of such remedial action being sustained in appeal are bright. The present system of routine re-course to section 154 should be gi .....

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