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2022 (4) TMI 459

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..... e to the outbreak of Covid-19 pandemic and the financial difficulties, petitioner was called upon to submit its written submissions utilizing the e-proceedings facility on or before 18/9/2020 - petitioner pointed out that despite uploading the written submissions of the petitioner as directed by the respondents, no orders on the appeal have been issued for the last more than 18 months - HELD THAT: .....

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..... und manner. As already more than 18 months have elapsed since the petitioner was directed by the respondents to upload the hearing note which it had in fact done, and even after that, the respondents failed issue the final order in the appeal, interests of justice demands that recovery proceedings ought not to be pursued in the meantime. The respondent or the Competent Appellate Authority must .....

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..... pointed out that despite uploading the written submissions of the petitioner as directed by the respondents, no orders on the appeal have been issued for the last more than 18 months. 2. According to the learned counsel, while the appeal is thus pending consideration, petitioner is served with Ext.P10 notice demanding payment of amounts imposed under Ext.P1 order of assessment. The learned cou .....

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..... 9 pandemic were introduced, including lockdown. Situation changed thereafter. This fact was noticed by the Income Tax Department itself, as seen from Ext.P6 notice, wherein they directed the petitioner to submit the written submissions electronically in the e-proceedings facility on or before 18/09/2020. Though there was few days delay, petitioner had uploaded the written submissions by 3/10/2020. .....

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..... ompetent Appellate Authority must be directed to consider and dispose of the appeal in a time bound manner. 7. Accordingly, I direct the 2nd respondent or the Competent Appellate Authority to consider and dispose of Ext.P3 appeal after granting an opportunity of hearing to the petitioner, as expeditiously as possible, at any rate, within three months from the date of receipt of a copy of this j .....

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