2021 (6) TMI 1008

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....ct") on the ground that there is no appeal pending in the case of Petitioner. 2. It is the case of Petitioner that Assessment Order for Assessment Year 2014-15 was passed under Section 144 read with Section 147 of the Income Tax Act, 1961 on 26th December 2019. Being aggrieved by the said order, Petitioner had filed an appeal before the concerned Commissioner of Income Tax (Appeals) on 6th February 2020 and BY an application for condonation of delay on 20th February 2020. Thereafter, in view of the enactment of the DTVSV Act, Petitioner had made an application by way of a declaration in Form 1 and an undertaking in Form 2 to the designated authority on 18th December 2020 and a revised declaration and undertaking on 29th January 2021. It ....

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....on Panel has not issued any direction on or before the specified date; (iv) a person in whose case the Dispute Resolution Panel has issued direction under sub-section (5) of section 144C of the Income-tax Act and the Assessing Officer has not passed any order under sub-section (13) of that section on or before the specified date; (v) a person who has filed an application for revision under section 264 of the Income-tax Act and such application is pending as on the specified date." 4. The issue at hand revolves around Section 2(1)(a)(i) as quoted above i.e., if the appeal before the appellate forum, CIT(A) in this case, is pending before the specified date i.e. 31st January 2020, then the applicant would be an eligible a....