2023 (9) TMI 117

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....des i/b. Mr. Ashish Mehta. For the Respondent nos. 2 to 4 : Mr. Suresh Kumar. P.C. : 1. Petitioner is impugning an order of rejection passed by respondents rejecting petitioner's application under the Direct Tax Vivad Se Vishwas Act, 2020 (DTVSV Act). 2. Petitioner, for Assessment Year 2001-2002, had filed its return of income on 29th October 2001. The return of income was processed un....

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....5 and 8th November 2016. By an order dated 28th February 2017 the application for condonation of delay came to be rejected by the ITAT. 3. Petitioner filed an appeal in this Court on 24th August 2017 impugning rejection of the application for condonation of delay by the ITAT. This Court was pleased to dismiss the appeal on 28th January 2020. Petitioner received the certified copy of the order o....

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....rdingly, the application of the assessee is hereby rejected". It is at that stage, petitioner has approached this Court by filing this writ petition. 5. Under the DTVSV Act, Section 4(1) provides that "the declaration referred to in Section 3 shall be filed by the declarant before the designated authority in such form and verified in such manner as may be prescribed". Section 4(2) provides that....

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.... an order has been passed by the Assessing Officer, or an order has been passed by the Commissioner (Appeals) or the Income Tax Appellate Tribunal in an appeal, or by the High Court in a writ petition, on or before the specified date, and the time for filing any appeal or special leave petition against such order by that person has not expired as on that date. Ms. Sathe submitted that the word "Wr....