(1) Notwithstanding anything contained in any provision of this Act, where an agreement is not reached, wholly or in part, the assessee may prefer an appeal—

(a) to the Commissioner of Taxes (Appeals) or Additional Commissioner of Taxes (Appeals) or Commissioner of Taxes (Appeals), as the case may be, where the dispute arises out of an order of a Deputy Commissioner of Taxes;

(b) to the Taxes Appellate Tribunal where the dispute arises out of an order of Additional Commissioner of Taxes (Appeals) or Commissioner of Taxes (Appeals), as the case may be;

(c) to the respective Appellate Authority or Court from where the assessee-applicant has got permission to apply for Alternative Dispute Resolution.

(2) In computing the period of limitation for filing appeal, the time elapsed between the filing of the application and the decision or order of the Alternative Dispute Resolution shall be excluded.