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Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
The HC set aside the appellate order rejecting the appeal as time-barred because the authority failed to consider the petitioner's pleaded grounds for condonation of delay, including the assertion that filing was delayed due to counsel's mistake after documents had been handed over. Rejection of limitation without dealing with these material explanations amounted to non-consideration of relevant contentions and a non-reasoned decision. The matter was remitted to the appellate authority for fresh consideration in accordance with law after notice to the petitioner.
The HC set aside the appellate order rejecting the appeal as time-barred because the authority failed to consider the petitioner's pleaded grounds for condonation of delay, including the assertion that filing was delayed due to counsel's mistake after documents had been handed over. Rejection of limitation without dealing with these material explanations amounted to non-consideration of relevant contentions and a non-reasoned decision. The matter was remitted to the appellate authority for fresh consideration in accordance with law after notice to the petitioner.
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