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2023 (6) TMI 670 - CALCUTTA HIGH COURTCondonation of delay in appeal filed by the revenue - delay of 1223 days - decision to file an appeal was taken by the department much after the decision of this Court in the case of Principal Commissioner of Income Tax-5 v. Swati Bajaj [2022 (6) TMI 670 - CALCUTTA HIGH COURT] - HELD THAT:- The appellant/department having not been diligent cannot now take advantage of the decision of Swati Bajaj and state that the delay of 1223 days has to be condoned. The law of limitation will not assist the person who is not diligent of his right. There is no separate law of limitation for the Government nor any latitude can be shown to the Government as the Government is as good as any other litigant and said to be the largest litigant. Revenue could not file appeal only to take the advantage of recent High court decision. Decided against revenue.
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