Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Delay in filing of appeal - receipt of order after 2 years - At the relevant time there was no provision for sending the order by speed post. - The Commissioner (Appeals) was, therefore, was not justified in observing that since the order was sent by speed post on 16 January 2012, it should be deemed to have been served on the appellant within 15-20 days from the date of dispatch.
Delay in filing of appeal - receipt of order after 2 years - At the relevant time there was no provision for sending the order by speed post. - The Commissioner (Appeals) was, therefore, was not justified in observing that since the order was sent by speed post on 16 January 2012, it should be deemed to have been served on the appellant within 15-20 days from the date of dispatch.
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