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    <description>COVID-19 limitation extensions were applied to treat the first appellate appeal as within time, as both the assessment order and the appeal filing fell within the Supreme Court&#039;s suo motu suspension period. The note also states that a notice under section 143(2) was issued beyond the prescribed limitation and before the transfer of jurisdiction under section 127 took effect, creating both time-bar and jurisdiction defects. On that basis, the notice was invalid and the assessment founded on it was quashed.</description>
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