2023 (2) TMI 1135

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....Petitioner : Mr Salil Kapoor, Mr Sumit Lalchandani & Ms Ananya Kapoor, Advocates. For the Respondents : Mr Abhishek Maratha, Sr. Standing ORDER [Physical Hearing/Hybrid Hearing (as per request)] CM APPL. 4721/2023 1. Allowed, subject to the petitioner filing legible copies of the annexures, at least three days before the next date of hearing. W.P.(C) 1243/2023 & CM APPL. 4720/202....

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....to accord time to an assessee "not less than seven days and but not exceeding thirty days from the date on which the notice is issued...". 5. Mr Kapoor submits that the expression "not less than seven days" commences from the date when the notice was issued, which will take the time required to be granted beyond 17.03.2022. 5.1 In support of his plea, Mr Kapoor has relied upon the judgment o....

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.... are counted. In other words, till the last minute of the seven years' period is completed the period remains less than seven years. In the present case the agreement was entered on 1-8-1964. The last instalment was to be paid on 31-7- 1971. The seven years were to complete at 12 A.M. (between the night of 31-7-1971 and 1-8-1971). Even if the loan was paid back at 11.59 P.M. on 31-7-1971 the p....

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....on the designated portal, and therefore, the reliance on the email dated 12.03.2022 by the petitioner/assessee will not help its cause. 7. In this context, we have queried Mr Maratha as to whether a real-time alert was sent to the petitioner via SMS. 7.1. Mr Maratha says that he will ascertain as to whether or not the notice was, firstly, uploaded on the designated portal and also whether a ....