2024 (5) TMI 1462

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..... ady been held to be excluded for all intents and purposes as per hon ble apex court s directions in Cognizance for Extension of Limitation, In re [ 2021 (11) TMI 387 - SC ORDER] read with judgment in Cognizance for Extension of Limitation, In re [ 2021 (3) TMI 497 - SC ORDER] and [ 2020 (5) TMI 418 - SC ORDER] , under the limitation law. This being the clinching factual position emanating from the .....

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..... u/s. 144 of the Income Tax Act, 1961 (in short the Act ). Heard both the parties at length. Case file perused. 2. It emerges at the outset that the learned NFAC herein has refused to condone the delay of 727 days in filing of the lower appeal instituted on 22.01.2022, against the assessment order dated 27.12.2019 despite the fact that the entire foregoing period i.e., from date of assessment comi .....

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