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2023 (9) TMI 494

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..... volved goes way beyond the statutory timeline fixed for the disposal of a rectification application. This is also the position that obtains as per Instruction No. 1 of 2016 dated 15.02.2016. That said, we find it difficult to understand why the petitioner did not approach the Court within a reasonable period. Repeated representations to the Assessing Officer (AO) and grievances sought cannot ex .....

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..... awhney with Mr Nihil Agarwal and Mr Puru Medhira, Advocates. For the Respondent Through: Mr Abhishek Maratha, Sr. Standing Counsel with Mr Akshat Singh, Standing Counsel. RAJIV SHAKDHER, J.: (ORAL) 1. Issue notice. 2. Mr Abhishek Maratha, learned senior standing counsel who appears on behalf of the respondents/revenue, accepts notice. 3. Given the directions that we propos .....

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..... ng with applicable interest under Section 244A of the Act within the said four weeks. 5. A perusal of the prayer clause would show that the petitioner is aggrieved by the fact that its rectification application dated 25.05.2016 has not been disposed of, as yet. 6. As rightly averred by the petitioner, the timeline fixed under sections 154(a) and 154(8) of the Income Tax Act, 1961 [in shor .....

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..... O will bear in mind that the first representation to the respondent was made on 09.10.2019. We are therefore, of the opinion that interest between the period after the expiry of six (6) months from when the rectification application was filed and 09.10.2019 in the facts of this case, ought not to be paid to the petitioner. 8. Parties will act based on the digitally signed copy of the order. .....

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