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    <title>2022 (12) TMI 948 - CALCUTTA HIGH COURT</title>
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    <description>Delay in filing the appeal was condoned after the explanation was found satisfactory. The retrospective amendment to the Income Declaration Scheme, 2016, together with the subsequent notification, was treated as enabling fresh administrative consideration because the third instalment had been paid with interest before the notified cut-off date and the earlier representation remained undecided. The assessee was therefore permitted to submit a fresh representation, the authority was directed to decide it by a speaking order on merits and in accordance with law, and coercive recovery was restrained until that decision.</description>
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      <description>Delay in filing the appeal was condoned after the explanation was found satisfactory. The retrospective amendment to the Income Declaration Scheme, 2016, together with the subsequent notification, was treated as enabling fresh administrative consideration because the third instalment had been paid with interest before the notified cut-off date and the earlier representation remained undecided. The assessee was therefore permitted to submit a fresh representation, the authority was directed to decide it by a speaking order on merits and in accordance with law, and coercive recovery was restrained until that decision.</description>
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