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The High Court addressed the issue of extending stay beyond 365 days by ITAT under the third proviso to Section 254(2A) with the 2008 Finance Act amendment. The amendment allowed for extension even if delay isn't the assessee's fault. The Delhi High Court initially invalidated the provision, but the Supreme Court upheld it in the Pepsi Foods Ltd. case. The High Court found the matter settled by the Supreme Court's ruling, upholding the tribunal's decision and dismissing the appeal.
The High Court addressed the issue of extending stay beyond 365 days by ITAT under the third proviso to Section 254(2A) with the 2008 Finance Act amendment. The amendment allowed for extension even if delay isn't the assessee's fault. The Delhi High Court initially invalidated the provision, but the Supreme Court upheld it in the Pepsi Foods Ltd. case. The High Court found the matter settled by the Supreme Court's ruling, upholding the tribunal's decision and dismissing the appeal.
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