2025 (2) TMI 294

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.... Petitioner : Mr. Jagabandhu Sahoo, Senior Advocate Ms. Kajal Sahoo, Advocate. For the Opposite Parties : Mr. S.C. Mohanty, Senior Standing Counsel Mr. A. Kedia, Junior Standing Counsel. JUDGMENT ARINDAM SINHA, ACJ. 1. Mr. Sahoo, learned senior advocate appears on behalf of petitioner-assessee. He submits, impugned is notice dated 25th July, 2024 of attachment. He points out from the n....

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.... in ITA no.426/M/2018 (M/s. Asterix Reinforced Ltd., v. Income Tax Officer) had in similar facts relegated to the First Appellate Authority, admission of appeal in electronic form on condoning delay. He seeks likewise direction upon the First Appellate Authority to permit his client to file appeal in electronic form and admit the same on condoning the delay. 5. Mr. Mohanty, learned advocate, Se....

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....l in Mumbai had dealt with the situation by requiring appellant therein to file the appeal with accompanying direction on condonation of delay. In this case petitioner has causes for consideration and satisfaction obtained, to apply on filing e-appeal, for condonation of delay in not having so filed earlier. Fact of appeal filed manually within time is a relevant fact to be considered. 7. On qu....

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...., if satisfied, to admit the appeal and adjudicate thereon. 8. Mr. Sahoo submits, there is also involved assessment year 2012- 13 in impugned attachment notice, appeal against which was decided on merits. Our direction regarding stay of operation of impugned attachment notice is excluding the attachment pursuant to First Appellate order in respect of assessment year 2012-13. We record that we h....