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This becomes a very relevant question of fact, one which is critical todetermine the question of limitation, in this case thus, a mixed question of law and fact. Thus, and in the absence of necessary facts, we find nothing untoward in the conclusion of the Tribunal rejecting the plea of limitation raised for the first time before it, particularly in the absence of any supporting material. We answer the substantial questions of law in favour of the Department and against the assessee. 18. This Civil Miscellaneous Appeal and the connected Miscellaneous Petition are dismissed. No costs. (A.S.M.,J.) (P.D.B.,J.) 02-01-2026 Index: Yes
by Sekar Reporter · Published January 14, 2026
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N.Ramesh respondent Petitioner adv Ajay goesh-The WP No. 7670/2020 came up for admission as Item No.2 on the 18th May, 2020 before the DB of Hon’ble Mr. Justice M. Sathyanarayanan and Dr. Justice Anita Sumanth. N Ramesh, Senior Panel Counsel appeared for Govt. of India. The writ petition was filed for the following relief:
by Sekar Reporter · Published May 18, 2020