TMI Blog2020 (11) TMI 459X X X X Extracts X X X X X X X X Extracts X X X X ..... to be treated as an assessee not in default in terms of the provisions of section 201[1]? - HELD THAT:- Tax Case appeals are closed, substantial questions of law are left open. Liberty is granted to the revenue to challenge the impugned order [ 2019 (1) TMI 1822 - ITAT CHENNAI] as well as the order that may be passed in the miscellaneous petitions filed before them. In the event, revenue is uns ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - - Dated:- 12-10-2020 - Honourable Mr. Justice T.S. Sivagnanam And Honourable Mrs. Justice V. Bhavani Subbaroyan For the Appellant : Mr.J.Narayanaswamy Senior Standing Counsel For the Respondent : Mr.Ashokpathy COMMON JUDGMENT T.S.SIVAGNANAM, J. These appeals, at the instance of the revenue filed under Section 260A of the Income Tax Act, 1961 (the 'Act' for br ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ons of section 201[1] of the Act? 3. Whether the Appellate Tribunal was right in relying upon the certificate in Form No.26A without considering the fact that all the three clauses of Section 201(1) should be satisfied for considering the assessee not in default for non-deduction of tax as required under Chapter XVIIB of the Income Tax Act? 3. We have heard Mr.J.Narayanasamy, learned sen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tions filed before them. In the event, revenue is unsuccessful, this observation is made because, if the revenue is unsuccessful before the Tribunal, they would be required to file two appeals, for each of the assessment year, one challenging the order dated 09.01.2019 impugned in these appeals and another appeal is against the order in the miscellaneous petitions. In such event, this observation ..... X X X X Extracts X X X X X X X X Extracts X X X X
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