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of Rejection of application under Direct Tax Vivad Se Vishwas Act, 2020 (DTVSVA) - Appellant / Assessee has filed an appeal with the application for condonation of delay where the period for filing an appeal was already expired - Section 2(1)(a) of the 2020 Act does not stipulate that the appeal should be admitted before the specified date, it only adverts to its pendency. - HC
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