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Supreme Court excludes the period starting from 15-3-2020 till 28-2-2022 from limitation period of all judicial proceedings before the Courts/Tribunals. all persons shall have a limitation period of 90 days from 1-3-2022. In the event the actual balance period of limitation remaining, with effect from 01.03.2022 is greater than 90 days, that longer period shall apply.
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Kindly note Supreme Court in Vodafone Idea on 29th April 2020 held that there is assessment year wise regime in processing of refund u/s 143(1)
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Though the limitation period is available for passing the order, not for service but as per the settled issue, the order must be served on the assessee within the reasonable time otherwise Order is Annulled.
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Nov 8, 2019-ITAT VISHAKAPATNAM hold that The additional ground is admitted if it goes to the root of the order.