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    <title>2025 (2) TMI 1822 - ITAT COCHIN</title>
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    <description>Where an assessee shows by affidavit that the assessment order came to knowledge only when recovery proceedings began, and there is no contrary material, the date of knowledge may be treated as the relevant date of receipt for limitation purposes. On that basis, the appeal before the CIT(A) was held to be within time, and the refusal to condone delay was set aside because the CIT(A) had declined to entertain the appeal without examining the merits. The matter was remanded to the CIT(A) for fresh adjudication on merits after giving the assessee a reasonable opportunity of being heard.</description>
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    <pubDate>Thu, 06 Feb 2025 00:00:00 +0530</pubDate>
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      <title>2025 (2) TMI 1822 - ITAT COCHIN</title>
      <link>https://www.taxtmi.com/caselaws?id=468609</link>
      <description>Where an assessee shows by affidavit that the assessment order came to knowledge only when recovery proceedings began, and there is no contrary material, the date of knowledge may be treated as the relevant date of receipt for limitation purposes. On that basis, the appeal before the CIT(A) was held to be within time, and the refusal to condone delay was set aside because the CIT(A) had declined to entertain the appeal without examining the merits. The matter was remanded to the CIT(A) for fresh adjudication on merits after giving the assessee a reasonable opportunity of being heard.</description>
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      <pubDate>Thu, 06 Feb 2025 00:00:00 +0530</pubDate>
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