2025 (1) TMI 376

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..... the CIT(A)/NFAC herein has even included the time period of Covid - 19 Pandemic outbreak on 15th March, 2020 till the date of filing of the appeal coming to 30th September, 2021 despite the fact that hon ble apex court s landmark decision in Re: Cognizance for Extension of Limitation [ 2022 (1) TMI 385 - SC ORDER ] has already directed exclusion thereof. We deem it appropriate to clarify that this .....

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..... .03.2024 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as the Act ). 2. Heard both the parties at length. Case file perused. 3. It emerges at the outset with the able assistance coming from both the parties that CIT(A)/NFAC has refused to admit the assessee s appeal instituted on 30th September, 2021 against the assessment herein dated 30.12.2019 o .....

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..... sidered view in these peculiar facts and circumstances that larger interest of justice would be met in case the assessee s instant appeal is restored back to the Assessing Officer for his afresh appropriate adjudication as per law subject to a rider that he shall plead and prove his case within three effective opportunities at her own risk and responsibility, in consequential proceedings. Ordered .....

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