2024 (9) TMI 535

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..... iling the appeal. Though the delay is explained by stating that the matter was being agitated before the learned Writ Court, in any event, an application under Section 5 of the Limitation Act has to be filed. The appellant/assessee is granted liberty to file such application and such application being filed, the department is directed to compute the delay and then list the application for hearing. .....

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