2025 (9) TMI 1481

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....R") submitted that the draft assessment order was received by the assessee on 12/3/2024, therefore, the due date for filing the objections before the learned Dispute Resolution Panel, Bengaluru ("learned DRP") was 11/4/2024, but since the last date, namely, 11/4/2024 happened to be a Public Holiday for the Central Government Offices, being the festival day of Id-ul-Fitr, the assessee sent an email on 11/4/2024 and filed the physical copy on 12/4/2024, but the learned AO held that there is no provision in the Act for the learned DRP to condone the delay and therefore, while holding that the assessee did not adhere to the requisitions as per Rule 4(3) and declined to admit the objections and rejected the same. 3. Learned AR placed reliance....

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....ed in the order that Form-35A was filed on 12/4/2024. Contention of the learned DRP, however, was that there is no provision in the Act for the learned DRP to condone the delay and therefore, learned DRP cannot condone even one day's delay. Precisely this is the reason for rejecting the objections filed by the assessee. 6. It is not in dispute that 11/4/2024 was a festive day of Id-ul-Fitr and was a Public Holiday to the Central Government Offices. Such circumstances are taken care by section 10 of the General Clause Act, 1897, which reads as under: - "10. Computation of time .- (1) Where, by any 1 [Central Act] or Regulation made after the commencement of this Act, any act or proceeding is directed or allowed to be done or ....