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Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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The HC sustained rejection of a revision application filed with a delay of 1,460 days because the explanation of partner disputes was vague and did not establish sufficient cause. It noted that the firm continued to comply with statutory obligations, including audits and return filing, during the alleged period of impediment, showing no inability to file on time. As the Commissioner's view on unexplained delay was a plausible one, no interference was warranted in writ jurisdiction. The Court also held that, once delay was the ground of rejection, the authority should not have commented on merits; those observations were directed to be ignored and not treated as precedent.
The HC sustained rejection of a revision application filed with a delay of 1,460 days because the explanation of partner disputes was vague and did not establish sufficient cause. It noted that the firm continued to comply with statutory obligations, including audits and return filing, during the alleged period of impediment, showing no inability to file on time. As the Commissioner's view on unexplained delay was a plausible one, no interference was warranted in writ jurisdiction. The Court also held that, once delay was the ground of rejection, the authority should not have commented on merits; those observations were directed to be ignored and not treated as precedent.
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