2023 (6) TMI 670

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....for the appellant Mr. Avratosh Majumdar, Sr. Adv. Mr. Somya Kejriwal, Adv. Mr. Indranil Banerjee, Adv. ...for the respondent ORDER The Court : We have heard Mr. Tilak Mitra, learned standing counsel for the appellant/revenue and Mr. Avtatosh Majumdar, learned senior counsel assisted by Mr. Soumya Kejriwal and Mr. Indranil Banerjee, learned Advocates for the respondent/assessee and perused....

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....ncome Tax-5 v. Swati Bajaj reported in 2022 SCC Online Cal 1572. The appellant/department having not been diligent cannot now take advantage of the decision of Swati Bajaj and state that the delay of 1223 days has to be condoned. The law of limitation will not assist the person who is not diligent of his right. That apart, there is no separate law of limitation for the Government nor any latitude ....