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Therefore, it is apparent on the facts and circumstances of the present case, that a mere typographical error committed by the assessee cannot cost them payment of excess tax as collected by the Revenue. Certainly, the denial for repayment of such excess collection would amount to great injustice to the assessee.

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Section 264 of the Income Tax Act, 1961 — Revision — Only suo moto power of the CIT under section 264 is restricted against an order passed within one year whereas no such restriction is imposed on the CIT to exercise his power in repsect of an order, which has been passed more than one year before, if such revisional power is sought to be invoked at the instance of the assessee by making an application under section 264 — Sharp Tools vs. Principal Commissioner of income tax [2019] 311 CTR (Madras) 505

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