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2019 (8) TMI 702 - AT - Income TaxReopening of assessment u/s 148 - period of limitation - HELD THAT:- As far as bar of limitation is concerned, we find from the perusal of records that the delay in filing of the appeals was explained in writing (in identically worded three separate letters) - we decline to dismiss the appeals on grounds of limitation. On merits, we find that Ld. CIT(A) has passed speaking orders. Relevant portions of the impugned orders of the Ld. CIT(A) have already been reproduced in foregoing paragraph (B) of this order. During appellate proceedings in Income Tax Appellate Tribunal (“ITAT”, for short) no material has been brought for our consideration to persuade us to take a view different from the view taken by the Ld. CIT(A) in the impugned order. After hearing the Ld. DR and after perusal of materials on record, and further, in view of the foregoing discussion, we decline to interfere with the impugned orders of Ld. CIT(A). In view of the foregoing discussion, the three appeals filed by assessee are dismissed. Assessee will be at liberty to approach ITAT for restoration of the appeals in accordance with Proviso to Rule 24 of Income Tax (Appellate Tribunal), Rules, 1963. If the assessee does approach ITAT for restoration of the appeals in ITAT, the matter will be considered in accordance with law having regard to the facts and circumstances.
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