TMI Blog2025 (1) TMI 1198X X X X Extracts X X X X X X X X Extracts X X X X ..... show cause notice, the time spent during the pendency of the writ petition as well as the date from which this appeal was filed till it is disposed by this order, has to be excluded. Instead of making an arithmetical calculation in this regard, we extend the time for submitting the reply to the show cause notice by a period of sixty days from the date of receipt of the server copy of this judgmen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CE And ( HIRANMAY BHATTACHARYYA , J. ) Mr. Abhratosh Majumdar, Sr. Adv. Mr. B.L. Narasimhan Mr. Rahul Tangri Mr. Pratyush Jhunjhunwala Mr. Deepro Sen Ms. Tania Roy ….For the Appellant Mr. Vipul Kundalia Mr. Jasojeet Mukherjee ….For the Respondent No.1 ORDER 1. This intra-Court appeal by the writ petitioner is directed against the order dated 23.12.2024 in WPA 24534 of 2024. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the writ petition was filed on 23.09.2024 and the matter was heard and the judgment was reserved on 09.12.2024 and the judgment was pronounced on 24.12.2024 and immediately thereafter, the present appeal has been filed. Since the appellant seeks to pursue the statutory remedy by submitting the reply to the show cause notice, the time spent during the pendency of the writ petition as well as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tions stand deleted and the appellant/assessee would be entitled to raise all contentions, both factual and legal, before the Adjudicating Authority. 5. In the light of the above order extending the time for submitting the reply to the show cause notice, the hearing which was fixed by the Adjudicating Authority, shall stand deferred. 6. Accordingly, the appeal and the connected application are d ..... X X X X Extracts X X X X X X X X Extracts X X X X
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