2025 (7) TMI 272

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.... the Appellant:- Mr. Vinay Kr. Shraff Ms. Priya Sarah Paul Mr. Dev Kr. Agarwal Ms. Swarnwarshi Poddar Ms. Ankita Biswas. For the Respondents:- Mr. Uday Sankar Bhattacharya Mr. Kaushik Dey Mr. Tapan Bhanja. JUDGMENT PER T. S. SIVAGNANAM, CHIEF JUSTICE.: 1. This intra court appeal has been filed by the writ petitioner challenging the order passed by the learned Single Bench in WPA 5232 o....

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....estion would be whether the case on hand would fall within any one of such exception in circumstances. 7. It is not in dispute that the appellant was given adequate opportunity to put forth its submissions even prior to the show cause notice when statements were recorded and after the show cause notice was issued, reply was submitted and the matter was adjudicated following the provisions under....

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....r passed the nonapplication of mind. 12. Thus, the three broad exceptions are not applicable to the instant case. 13. That apart, the issues which have been canvassed in the writ petition as well as before us all requires adjudication into disputed questions of fact. The length of the delay in filing the returns appears to be not sole issue in the instant case but there is something more tha....