2022 (9) TMI 362

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ant. Mr. Prithu Dudhoria, Adv. ... for Respondents ORDER The Court : We have heard Mr. Indranil Banerjee, learned Counsel appearing for the appellant and Mr. Prithu Dudhoria, learned Counsel appearing for the respondent. There is a delay of 91 days in filing the appeal. We have perused the affidavit filed in support of the application for condonation of delay and we find sufficient cau....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.....com 64 (SC), a notice issued under Section 148 prior to the amendment, all stand validated and is deemed to have been issued under the new law and the authorities were directed to proceed in terms of the amended Section 148A of the Act. Learned Counsel appearing for the appellant placed reliance on the decisions in Urmilaben Anirudhasinhji Jadeja vs. Income-tax Officer, (2020) 117 taxmann.com ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e, 2022, which related to a penalty proceedings against a dead person and the order impugned in the said appeal was passed by the Tribunal affirming the order passed by the Commissioner of Income Tax (Appeals) interfering with such an order of penalty passed against a dead person. The said order of the Tribunal was affirmed by this Court in its judgment dated 27th June, 2022. From the aforement....