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2019 (11) TMI 936

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..... hould be treated that no such decision is taken in the eye of law. However, as it is communicated through the impugned proceedings dated 12.06.2018 that the Revision Application filed by the petitioner was already rejected on 03.03.2016, this Court is of the view that it is better for the first respondent to consider the matter afresh including the question of limitation by giving an opportunity o .....

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..... ORDER This writ petition is filed challenging the communication dated 12.06.2018 issued by the first respondent informing the petitioner that Revision Application filed under Section 264 of the Income Tax Act, 1961 for the Assessment Years 2000-01 to 2012-13 was already disposed of as Void ab initio on 03.03.2016, since the said application was filed more th .....

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..... n 264 of the said Act, raising some dispute. 5. This Court, at this stage, is not expressing any view on the merits of such dispute raised by the petitioner under Section 264, for the simple reason that the first respondent has chosen to reject the said revision petition only on the ground of limitation. However, it is not in dispute that the decision taken by the first respondent .....

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..... sidering the above stated facts and circumstances, this Court, is of the view that a decision taken is not communicated, it should be treated that no such decision is taken in the eye of law. However, as it is communicated through the impugned proceedings dated 12.06.2018 that the Revision Application filed by the petitioner was already rejected on 03.03.2016, this Court is of the view that it is .....

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