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2022 (6) TMI 1504

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....pondent : Mr. S. M. Surana, Adv., Mr. Anil Kumar Dugar, Adv. And Mr. Rajarshi Chatterjee, Adv. The Court : We have heard Ms. Smita Das De, learned standing counsel for the appellant/revenue and Mr. S. M. Surana, learned counsel assisted by Mr. Anil Kumar Dugar and Mr. Rajarshi Chatterjee, learned Advocates for the respondent/assessee. There is a delay of 1178 days in filing the appeal. The respo....

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....ement giving certain dates and events. It may not be necessary for us to take into all the dates and events post 14th September, 2018 as the period of limitation for filing the appeal expired on 3rd September, 2017. Therefore, if the department has to make out a case, they should explain the delay from 3rd September, 2017 and the department has sought to explain the delay after 14th September, 201....

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.... of 532 days in filing the appeal was refused to be condoned as the Hon'ble Supreme Court took note of its earlier decision in the State of Madhya Pradesh vs. Bherulal, reported in [2020] 10 SCC 654 wherein the Court discouraged the State Government and public authorities in adopting an approach that they can walk into the Hon'ble Supreme court as and when they please ignoring the period of limita....