2022 (7) TMI 1395

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....ppellant. Mr. Pratyush Jhunjhunwalla, Mr. M. Kejriwal, Adv for respondent. RE: GA/1/2022 The Court : There is a delay of 757 days in filing the appeal. On perusal of the relevant dates we find that the appellant/revenue be entitled to the benefit of the order passed by the Hon'ble Supreme Court extending the period of limitation for preferring appeals under various statutes. For suc....

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....cumstances of the case, ITAT was erred in law in confirming the decision of Ld. CIT[A], wherein it was observed that as per Finance Act, 2012, section 149[1][c] of the Act was made effective prospectively from 01.07.2012 and there was nothing expressly provided by amending Act which indicated Legislative intent to make provision of section 149[1][c] applicable, to those proceedings which had becom....

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....ore particularly, the decision in the case of BRAHM DATT VS. ASSISTANT COMMISSIONER OF INCOME TAX; REPORTED IN [2018] 100 TAXMANN.COM 324 [DELHI]. In the said decision it was held that the amendment of Section 149 of the Act by Finance Act, 2012, which extended limitation for reopening assessment to sixteen years could not be resorted for reopening proceedings concluded before amendment came into ....