2026 (8) TMI 1670

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....r>Income Tax<br>HON&#39;BLE MR. JUSTICE DINESH MEHTA AND HON&#39;BLE MR. JUSTICE RAJNEESH KUMAR GUPTA For the Appellant Through: Mr. Puneet Rai, SSC with Mr.Ashvini Kumar, Mr.Rishabh Nangia, JSCs and Mr.Nikhil Jain and Ms. Naincy Jain, Advs. For the Respondent Through: Mr.Neeraj Jain and Mr.Aniket D. Agarwal, Advs. ORDER CM APPL. 56466/2026 in ITA 674/2026 (delay of 45 days in filing t....

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....asmuch in paras 3 to 8 of the impugned order, it proceeded as if the assessee had appeared before the Dispute Resolution Panel (hereinafter referred to as "DRP"), whereas the respondent-assessee had taken the route of Appellate Authority i.e., Commissioner of Income Tax (Appeals) (hereinafter referred to as "CIT(A)"). 5. He submitted that immediately on receipt of the draft assessment order dat....

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.... have no bearing on the issue of limitation, since the law enjoined upon the Assessing Officer to pass the order within 30 days from the end of the month in which the Assessing Officer received the acceptance of the draft assessment order. 8. He argued that principles of limitation or the law laid down in the Roca Bathroom (supra) is equally applicable on the cases in which the assessee had tak....