8. It is true that there is huge delay of 2176 days in filing each of the first appeals before ld. CIT(Appeals). We, however, take judicial notice of the fact that most of the duration of delay caused in filing first appeals before Ld. CIT (A) overlaps the period of spread of global pandemic COVID-19. This fact has also been taken care of by Hon’ble Supreme Court in Misc. app. No. 21/2022 in Misc. app No. 665/2021 in suo-moto W.P(c) No. 3/2020 in civil original jurisdiction and in re cognizance of extension of limitation with miscellaneous application No. 29/2022, in miscellaneous application No. 655/2021 in suo- moto petition(c) no. 03/2020 and vide para 5(1) of its order dated 10.01.2022 directed that its order dated 23.03.2020 is restored and in continuation of the subsequent order dated 08.03.2021, 27.04.2021 and 23.09.2021, it is directed that the period from 15.03.2020 till 28.02.2022 shall stand excluded for the purpose of limitation as may be prescribed under any general or special laws in respect of all judicial or quasi judicial proceedings after exclusion of the aforesaid duration. Therefore, substantial part of the delay in filing the first appeals before ld. CIT(Appea