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2022 (11) TMI 255

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..... SRI NARASIMHA ] ORDER S. RAVINDRA BHAT , J. 1. By this application, the revenue seeks a clarification of the judgment dated 19.10.2022, delivered by this court, in CA 21762/2017 and connected appeals. The clarification sought is that para 254 of the judgment should be such as to "enable the Revenue to redo the assessments in accordance with the above judgments for the past and examine the elig .....

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..... e clarification it seeks is necessary, because in Para 253 H and in Para 254, it has been precluded from examining the facts and assessing the concerned assessment years, in relation to the assesses in these appeals. It was urged that the conclusions recorded in the judgment and those in the said two paragraphs, preclude it from dealing with the assessments of parties before this court and, furthe .....

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..... nue. However, in Para 254 (v), (vi), (vii) and (vii), the conclusions, are in favour of the revenue. 5. The reference to application of the law declared by this court's judgment, therefore, has to be understood in the context, which is that they apply for the assessment years in question, which were before this court and were decided; wherever the appeals were decided against the revenue, they ar .....

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