Dismissing the appeal of the revenue the Court held that when the delay in proceedings not attributable to assessee, the Tribunal has the power to grant stay even beyond period of 365 days. Referred, DY. CIT v. Pepsi Foods Ltd (2021) 433 ITR 295 (SC). (AY.2009-10)
PCIT v. Michelin India Pvt. Ltd. (2022) 442 ITR 268 (Mad.)(HC)
S. 254(2A) : Appellate Tribunal-Stay-Delay in proceedings not attributable to assessee-Tribunal has the power to grant stay even beyond period of 365 days. [S. 254(1)]