Denying extension of stay by ITAT beyond 365 days to 'well-behaved' assessee is unconstitutional: Hi

IT : Expression 'even if delay in disposing of appeal is not attributable to assessee' as inserted in third proviso to section 254(2A) by virtue of Finance Act, 2008 failed to achieve its object that assesses should not misuse stay orders granted in their favour by adopting delaying tactics, same is to be struck down