The Hon’ble Allahabad High Court in Wilh Loesch India Pvt. Ltd. v. Deputy Commissioner and Another [Writ Tax No. 2765 of 2026 dated May 27, 2026] quashed the appellate order dismissing the appeal solely on the ground of limitation, without entering into the merits, and held that once the Assessee discloses the actual date of communication of the adjudication order, the onus shifts on the Revenue to rebut the same through cogent material, and in the absence thereof, the date of communication as declared by the dealer shall be treated as the date of actual communication and the limitation shall arise from such date.
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