2009 (5) TMI 735

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..... appellants are un-represented Accordingly, I have heard Dr. M.K. Rajak, learned SDR and have gone through the impugned order passed by Commissioner (Appeals). 2. I find that the appellate authority has rejected the appeal on three different grounds. Firstly, there was a delay of 31 days in filing appeal and they have not filed any Condonation of Delay (COD) application. Thus, he has held that t .....

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..... ants have not been put to a notice on the ground of limitation and were not called upon to show as to why their appeal should not be disallowed on limitation ground. The appellant s explanation on this ground is not on record. I also further note that the appellants were given two weeks time to deposit the directed amount. The appellants have not explained in their memo of appeal as to why the sa .....

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