2024 (1) TMI 1137

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.... HIGH COURT - [2024] 464 ITR 89 (Mad)<br>MADRAS HIGH COURT - HC<br>Dated:- 23-1-2024<br>W. P. No. 4865 of 2023 And W. M. P. Nos. 4897 and 4899 of 2023 - -<br>Income Tax<br>Honourable Mr. Justice Senthilkumar Ramamoorthy For the Petitioner : Mrs.Revathi Manivannan For the Respondents : Mr.A.N.R.Jayaprathap, Jr.SC ORDER The petitioner challenges an order dated 18.11.2022 of the first respondent ....

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....that the application was filed beyond the time limit specified in guidelines issued by the Central Board of Direct Taxes on 14.06.2019. The present writ petition arises in the above facts and circumstances. 2. Learned counsel for the petitioner submitted that the impugned order warrants interference by this Court because the conclusion recorded therein is unsustainable. By pointing out that the i....

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....lication was filed within about eighteen months from the date of lodging of the complaint. 3. Even otherwise, learned counsel submitted that the guidelines issued by the Central Board of Direct Taxes on 14.06.2019 were quashed by this Court by order dated 03.11.2023 in W.P.Nos.2968 and 2970 of 2023. As a consequence, learned counsel contended that the compounding application may be filed at any t....

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....taking note of this aspect, the guidelines issued by the Central Board of Direct Taxes on 14.06.2019 were quashed by this Court. At this point of time, the said judgment holds the field. Even otherwise, the complaint was lodged on 03.01.2019. A period of about fifteen months lapsed between the date of complaint and the onset of the Covid-19 pandemic. If the period excluded under orders of the Hon&....