आदेश/ORDER

PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-

This appeal is filed by the Revenue as against the appellate order dated 23.09.2020 passed by the Commissioner of Income Tax (Appeals)-6, Ahmedabad arising out of the reassessment order passed under section 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2012-13.

2. The registry has noted that there is a delay of 34 days in filing the above appeal. This appeal is filed before the Tribunal on 15.01.2021, this period falls under COVID-19 Pandemic situation. Thus following Hon’ble Supreme Court judgment dated 23.3.2020 in suo moto Writ Petition (Civil) No.3 of 2020, which has extended time limit for filing appeals w.e.f. 15.3.2020. Thus, there is no delay in filing the above appeal by the Department and we take up the appeal for adjudication on merits.

3. The brief facts of the case is that assessee alo ng with other two co-owners purchased agricultural land at RS No.136 (Old RS No. 199