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    <title>Commissioner&#039;s Restrictive Timeline Interpretation Overturned; 30-Day Condonable Period Applies for Late Appeal Filing Under Section 128</title>
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    <description>HC determined the Additional Commissioner erred in adopting an overly restrictive interpretation regarding appeal filing timelines. The petitioner&#039;s contention that the appeal was timely filed despite delayed order receipt was upheld, as the 30-day condonable period provision could have been legitimately applied to hear the appeal on merits. The court emphasized that procedural technicalities should not override substantive justice. Accordingly, the Additional Commissioner&#039;s Order-in-Appeal dated 29 December 2023 was quashed and the petition was allowed, enabling consideration of the appeal on its substantive merits.</description>
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    <pubDate>Tue, 18 Feb 2025 08:10:06 +0530</pubDate>
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      <title>Commissioner&#039;s Restrictive Timeline Interpretation Overturned; 30-Day Condonable Period Applies for Late Appeal Filing Under Section 128</title>
      <link>https://www.taxtmi.com/highlights?id=85829</link>
      <description>HC determined the Additional Commissioner erred in adopting an overly restrictive interpretation regarding appeal filing timelines. The petitioner&#039;s contention that the appeal was timely filed despite delayed order receipt was upheld, as the 30-day condonable period provision could have been legitimately applied to hear the appeal on merits. The court emphasized that procedural technicalities should not override substantive justice. Accordingly, the Additional Commissioner&#039;s Order-in-Appeal dated 29 December 2023 was quashed and the petition was allowed, enabling consideration of the appeal on its substantive merits.</description>
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      <pubDate>Tue, 18 Feb 2025 08:10:06 +0530</pubDate>
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