9911796707
TMI Blog2023 (3) TMI 1051X X X X Extracts X X X X X X X X Extracts X X X X ..... ed:- 15-12-2022 X X X X Extracts X X X X X X X X Extracts X X X X ..... ). 45. (1) An appeal to the Commissioner (Appeals) shall be made in Form No. 35. (2) Form No. 35 shall be furnished in the following manner, namely: (a) in the case of a person who is required to furnish return of income electronically under sub-rule (3) of rule 12-- (i) by furnishing the form electronically under digital signature, if the return of income is furnished under digital signat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ure for electronic filing of Form No.35 and documents; (ii) specify the data structure, standards and manner of generation of electronic verification code, referred to in sub-rule (2, for the purpose of verification of the person furnishing the said form; and (iii) be responsible for formulating and implementing appropriate security, archival and retrieval of policies in relation to the said f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... gle Judge is extracted below: "14. In the present case, the manual appeal has, admittedly, been filed on time. The CIT(A) has also heard the matter on merits on two (2) occasions and written submissions of the petitioner are available on record. In such circumstances, I am of the view that the statutory right of appeal granted to the petitioner, a substantive right, should not be whittling down ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o reason to interfere with the impugned order passed by the learned Single Judge, inasmuch as it has been made clear that, in view of the peculiar facts and circumstances of the case and to preserve the right of appeal, the above directions were given while making it clear that this case shall not be treated as a precedent and the question as to whether Rule 45 of the Income Tax Rules must be trea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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