TaxTMI 
TaxTMI 
27 Aug 2026 
516 Views 
In the recent judgment in Tata Steel Limited Vs Union of India - 2026 (8) TMI 1587 - Supreme Court, Supreme Court after considering the extensions for furnishing annual returns and the exclusion of limitation granted by the Supreme Court during the COVID-19 pandemic in IN RE Cognizance for Extension of Limitation - 2021 (5) TMI 564 - SC Order, held that the limitation for the three subject financial years stood at 28.02.2025. The SCN dated 13.06.2025 was therefore beyond the limitation applicable under Section 73.
But the above decision contradicts its own judgment dated 19.6.2020 in Criminal Appeal No. 452 of 2020 (arising out of SLP-Crl No. 2433/2020 in the case of S. Kasi Vs State - 2020 (6) TMI 727 - Supreme Court through the Inspector of Police, Samaynallur Police Station, Madurai district, wherein the Honourable Supreme Court held as follows:-
"17. The limitation for filing petitions/ applications/ suits/ appeals/all other proceedings was extended to obviate lawyers/litigants to come physically to file such proceedings in respective Courts/Tribunals. The order was passed to protect the litigants/lawyers whose petitions/ applications/ suits/ appeals/all other proceedings would become time barred they being not able to physically come to file such proceedings. The order was for the benefit of the litigants who have to take remedy in law as per the applicable statute for a right."
How to reconcile this situation? Please discusses.
In M/s. Sahaj Constructions vs Union of India (2024 (10) TMI 1166 - KARNATAKA HIGH COURT), honourable Karnataka High Court held as follows:-
'15. In so far as the decision of the Hon'ble Apex Court in Misc. Application No. 21/2022 - 2022 (1) TMI 385 - SC Order relied upon by the counsel for the petitioner at para No.2 of the said judgment reads as under
'2. On 23.03.2020, this Court directed extension of the period of limitation in all proceedings before Courts/Tribunals including this Court w.e.f. 15.03.2020 till further orders. On 08.03.2021, the order dated 23.03.2020 was brought to an end, permitting the relaxation of period of limitation between 15.03.2020 and 14.03.2021. While doing so, it was made clear that the period of limitation would start from 15.03.2021'.
16. A perusal of the said above paragraph would indicate that the extension of the period of limitation in all proceedings before Courts and Tribunals is what was considered by the Hon'ble Apex Court in the said decision and not matters pertaining to assessment, reassessment, show cause notice or the like issued by tax Authorities. Thus, I am of the considered opinion that the decision of the Hon'ble Apex Court in suo motu proceedings referred to supra would also not be applicable to the present facts and circumstances.'
Please continue further discussion in view of the above interpretation
Thank you Sadanand garu.