2020 (11) TMI 459

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....ni Subbaroyan For the Appellant : Mr.J.Narayanaswamy Senior Standing Counsel For the Respondent : Mr.Ashokpathy COMMON JUDGMENT T.S.SIVAGNANAM, J. These appeals, at the instance of the revenue filed under Section 260A of the Income Tax Act, 1961 (the 'Act' for brevity), are directed against the orders passed by the Income Tax Appellate Tribunal, Madras 'A' Bench, Che....

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....e certificate in Form No.26A without considering the fact that all the three clauses of Section 201(1) should be satisfied for considering the assessee not in default for non-deduction of tax as required under Chapter XVIIB of the Income Tax Act?" 3. We have heard Mr.J.Narayanasamy, learned senior standing counsel for the appellant / revenue and Mr.Ashokpathy, learned counsel for the assessee. ....

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....he revenue is unsuccessful before the Tribunal, they would be required to file two appeals, for each of the assessment year, one challenging the order dated 09.01.2019 impugned in these appeals and another appeal is against the order in the miscellaneous petitions. In such event, this observation would come to the aid of the revenue while explaining the delay that may occasion in filing such appea....