10.The appellant filed a Miscellaneous Petition supported by an affidavit signed by the Managing Director of the appellant from which, we find that the appellant wanted extension of time for the respondent to pass appropriate orders, since the appellant was in the process of collating details of all pending litigations, which were initiated/pending prior to the acquisition of the appellant company by Ms/.Dhanuka Laboratories Ltd. This petition was considered and the learned Single Bench extended the time and subsequently, the appellant had filed this appeal before this Court and the appeal was not numbered immediately because, change of cause title has to be ordered and when the appeal was in the process of being numbered, it appears that the appellant had made an oral mention before the learned Single Bench for further extension of time. From the affidavit filed in support of the Miscellaneous Petition, seeking extension of time, which was filed during July 2021, we find that the appellant was agreeable to cooperate in the proceedings before the respondent. Nevertheless, the learned Single Bench while dismissing the writ petition, had taken note of all the facts and has recorded a prima facie view that the reopening is in order. However, there is no specific finding as regards the plea raised by the assessee that the reopening is a case of change of opinion.
