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In fact, if one contrasts s. 264 of the Act with s. 246A of the Act which provides for appeal, it would be noticed that unlike s. 246A of the Act which specifies sections of the Act from which an appeal would lie, s. 264 of the Act provides for revision from ‘any order’ under the Act. This is another indication that the CIT has very wide powers to correct any order passed by an officer subordinate to him.In the above view, we are not inclined to entertain this petition as an efficacious alternate remedy is available to the petitioner under the Act.

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Section 264 of the Income Tax Act, 1961 — Read with article 226 of the Constitution of India — Remedy of revision under section 264 is available against rejection of assessee's refund application. Writ petition was not therefore maintainable — Aditya Marine ltd vs. Deputy Commissioner of the income tax [2019] 311 CTR (Bombay) 695

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