Special Appeals delay condoned, Exemption applications allowed, Assessing Authority directed to proceed with re-assessment.

The delay in filing the Special Appeals was condoned, and the Exemption applications were allowed. The Court directed the Assessing Authority to proceed with the re-assessment order without being influenced by the Single Judge's observations. The appellant was granted the opportunity to submit additional arguments during the re-assessment proceedings. An extension of eight weeks was provided for passing the re-assessment order for one of the assessment years. The Special Appeals were disposed of without costs, and parties were to receive a certified copy of the order.

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Issues:
Delay Condonation Application
Common Order in Writ Petition
Re-assessment Notice under Income Tax Act
Appeal against Single Judge's Order
Influence of Single Judge's Findings on Re-assessment
Additional Submissions during Re-assessment
Extension of Period for Re-assessment

Delay Condonation Application:
The delay in preferring the Special Appeals was condoned as the applications were unopposed. The Delay Condonation Applications were disposed of, and Exemption applications were allowed.

Common Order in Writ Petition:
The Special Appeals were filed against a common order passed by the Single Judge in Writ Petition (M/S) No. 122 of 2013 and batch dated 19.07.2019. The appellant, a partnership firm, was assessed for the Assessment Years 2005-06 to 2008-09. After receiving a re-assessment notice in 2010, the appellant submitted objections, but no re-assessment order was passed by the Assessing Authority.

Re-assessment Notice under Income Tax Act:
The appellant challenged the order of the Assessing Authority dated 22.11.2011 by invoking the jurisdiction of the Court. The Single Judge dismissed the Writ Petitions on merits, leading to the filing of the Special Appeals.

Appeal against Single Judge's Order:
The counsel for the appellant argued that the Single Judge failed to address all contentions, and the findings might prejudice the re-assessment proceedings. Concerns were raised that the Assessing Authority could be influenced by the Single Judge's observations.

Influence of Single Judge's Findings on Re-assessment:
The Court directed the Assessing Authority to pass the re-assessment order without being influenced by the Single Judge's observations. The appellant sought the opportunity to file additional submissions during oral hearings of the re-assessment proceedings, which was granted.

Additional Submissions during Re-assessment:
The appellant was allowed to file additional submissions during the oral hearing of the re-assessment proceedings to ensure a fair opportunity to present their case.

Extension of Period for Re-assessment:
An extension of eight weeks was granted for passing the re-assessment order for the Assessment Year 2005-06 to accommodate the appellant's request for an oral hearing. The Assessing Authority was directed to inform the appellant of the hearing date for submissions.

In conclusion, the Special Appeals were disposed of without costs, and a certified copy of the order was to be supplied to the parties by a specified date.

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