Statutory timelines for disposal of income-tax appeals prevail over administrative circulars that assign priority categories for out-of-turn disposal. Where the prescribed timeline has not been followed, pending appeals must be decided expeditiously and cannot be deferred solely because they do not fall within an administrative priority category. The appellate authority must provide a proper and reasonable opportunity of hearing and dispose of the pending appeals within three months, without adjudication of their merits at this stage.
Statutory timelines for disposal of income-tax appeals prevail over administrative circulars that assign priority categories for out-of-turn disposal. Where the prescribed timeline has not been followed, pending appeals must be decided expeditiously and cannot be deferred solely because they do not fall within an administrative priority category. The appellate authority must provide a proper and reasonable opportunity of hearing and dispose of the pending appeals within three months, without adjudication of their merits at this stage.
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