2025 (6) TMI 1169

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....ndait, Advocate for the appellant Shri Priyesh Bheda, Joint Commissioner (AR) for the respondent ORDER PER : C J MATHEW This appeal lies against disposal of challenge that tax liability of Rs. 1,22,73,587 under section 73 of Finance Act, 1994, along with applicable interest under section 75 of Finance Act, 1994, and imposition of penalty under section 70, 77 and 78 of Finance Act, 1994....

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....d Representative. 4. We observe that the appeal has not been disposed off on merits but dismissed at the threshold on two counts, viz., for failing to make the prescribed pre-deposit and for not having filed the appeal within the period stipulated in Finance Act, 1994. 5. Insofar as the first of the deficiencies is concerned, the appellant has, since, made the pre-deposit to have appeal admi....

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....pt of impugned order. They also failed to explain how postal department has taken 169 to deliver the impugned order send by Speed Post. Thus, the claim that, impugned order dated 10.03.2023 was received by them on 28.08.2023 is not acceptable and the Appeal is held as time barred.' 7. The appellant has placed on record therein request for the order and its receipt on 28th August 2023. In the li....