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Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
section 263 of the Act was not appealable before this Tribunal since he was not advised by his Tax Consultant about this legal right. Later on, when a Senior Lawyer advised assessee to file an appeal, the assessee immediately took steps to file the appeal. Therefore, the delay caused. We note that delay was because of the wrong advice