2025 (1) TMI 127

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....ng to the prevailing difficulties during the COVID period, the petitioner could not submit a timely response to the said notice. 3. Consequently, an Adjudication Order was passed on 24th January 2023 by the respondent authorities. The petitioner claims that this order was not initially communicated or served upon it. 4. The petitioner only became aware of the adjudication order when it encountered difficulties operating its bank account. Upon contacting the bank, it was revealed that the petitioner's accounts had been frozen pursuant to the directions of the respondent department. 5. On becoming aware of the adjudication order, the petitioner submitted a representation dated 25th April 2024, recording its receipt of the order and rai....

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....ere genuine hardships are demonstrated, particularly in light of judicial precedents supporting such relief. 10. In S. K. Chakraborty & Sons Vs. Union of India reported in [2024] 159 taxman.com 259 (Calcutta), the Hon'ble Division Bench comprising Justice Debangsu Basak and Justice Md. Shabbar Rashidi held that: - "19. Section 107 of the Act of 2017 does not exclude the applicability of the Act of 1963 expressly. It does not exclude the applicability of the Act of 1963 impliedly also if one has to consider the provisions of Section 108 of the Act 2017 which provides for a power of revision to the designated authority, against an order of adjudication. In case of revision a far more enlarged period of time for the Revisional Authority to ....