2023 (6) TMI 670

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..... COURT ] - HELD THAT:- The appellant/department having not been diligent cannot now take advantage of the decision of Swati Bajaj and state that the delay of 1223 days has to be condoned. The law of limitation will not assist the person who is not diligent of his right. There is no separate law of limitation for the Government nor any latitude can be shown to the Government as the Government is .....

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..... n support of the application for condonation of delay as well as the affidavit-in-opposition of the respondent/assessee and the affidavit-in-reply filed by the revenue. There is a delay of 1223 days in filing the appeal. The order impugned in the appeal was passed by the learned Tribunal on 16th November, 2018 and the certified copy was received by the appellant/department on 20th December, 201 .....

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..... vernment as the Government is as good as any other litigant and said to be the largest litigant. Thus, for the above reasons, we are not persuaded to exercise in favour of the appellant/revenue. Consequently, the application for condonation of delay (IA No.GA/1/2022) is dismissed. Consequently, the appeal filed by the revenue (ITAT/189/2022) stands rejected and the application for stay (IA N .....

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