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    <title>2023 (4) TMI 1219 - CALCUTTA HIGH COURT</title>
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    <description>An appeal against tax proceedings was not treated as time barred because the earlier intimation and the assessee&#039;s reply had not been brought to a logical conclusion. The later proceeding arose on the same alleged liability while the earlier response remained pending in substance, so the limitation objection was not decisive. The question whether the later notice had been seen on the portal became academic, and the matter was required to be examined on merits rather than rejected on a technical ground. The appellate order was set aside and the appeal restored for hearing on merits.</description>
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      <description>An appeal against tax proceedings was not treated as time barred because the earlier intimation and the assessee&#039;s reply had not been brought to a logical conclusion. The later proceeding arose on the same alleged liability while the earlier response remained pending in substance, so the limitation objection was not decisive. The question whether the later notice had been seen on the portal became academic, and the matter was required to be examined on merits rather than rejected on a technical ground. The appellate order was set aside and the appeal restored for hearing on merits.</description>
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