PARADIP PORT TRUST Vs. UNION OF INDIA

JUDGEMENT

(1.) This matter is taken up by video conferencing mode.

(2.) Mr. R. V. Easwar, learned Senior counsel appearing for the Petitioner, points out that pursuant to a long drawn litigation concerning the Petitioner's request for grant of registration under Sec. 12 AA of the Income Tax Act, 1961 (Act) for the Assessment Years 2003-04, 2004-05 and 2005-06, the said registration was finally granted in favour of the Petitioner by an order dtd. 23/3/2017 of the CIT (E) Hyderabad.

(3.) Thereafter, pursuant to the Petitioner's repeated representations, a letter dtd. 24/6/2021 was received from the Deputy Commissioner of Income Tax (DCIT), Circle-1, Cuttack asking the Petitioner to submit the original income tax returns for the relevant AYs. Pursuant to this communication, the Petitioner submitted revised returns for the AYs in question. However, by the impugned order dtd. 28/9/2021 the DCIT has rejected the request of the Petitioner to give effect to the registration granted under Sec. 12AA on the ground that there is no provision to entertain such a request after lapse of 17 years.