High Court Rules Lockdown Delays Override Income Tax Act Limitations; Section 197 Application Restored for Reconsideration.

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....Application for a certificate u/s 197 - legality and validity of order issued by the first respondent u/s 119 - Application was rejected since the reply against the SCN could not be filed due to lockdown - Period of limitation - Extension of limitation period as provided by the Ordinance would have an overriding effect over the limitation provision contained in the Income Tax Act for the financial year relevant to the assessment year 2020-21. - Application restored for re-consideration - HC....