Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors.

2 SCC 107Supreme Court of India1987#157 most cited

What is Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors. authority for?

Courts must adopt a liberal approach when considering applications for condonation of delay, preferring to decide cases on their merits rather than allowing technicalities of limitation to scuttle justice. This principle applies to ensure the substantive rights of parties are not defeated by minor delays.

451

judgments rely on this decision, according to BharatTax’s citation analysis of 367,518 Indian tax judgments — from 2013 to 2026.

Also referred to as

Collector v. Katiji · Mst. Katiji · condonation of delay · delay in filing appeal · liberal approach · justice on merits · extension of limitation · reasonable cause · Section 250 · Section 147 · Section 148

Sections most often in play

Section 250Section 147Section 144Section 144BSection 142(1)Section 250(6)Section 143(3)Section 148

Issues it is cited on

extension of limitationreasonable causedelay in filing appealbest judgment assessmentsection 12a(1)(ac)(iii)section 250(6)section 12a(1)(ac)condonation of delaysection 12a(1)section 80g(5)service of noticesection 12ab

Judgments citing Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors.

Bharat Agarwal Nagari Sahakari Patsanstha Maryadit Lonavala, Lonavala vs. Income Tax Officer. Ward 9(5), Pune

In the result, appeal of the Assessee is allowed

ITA 1752/PUN/2025[2017]Status: DisposedITAT Pune18 Nov 2025

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Pramod S Shingte, CAFor Respondent: Shri Uodol Raj Singh, DR
Section 143(3)Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “A” BENCH : PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER & SHRI VINAY BHAMORE, JUDICIAL MEMBER I.T.A.No.1752/PUN/2025 (Assessment Year 2017-2018) Bharat Agarwal Nagari ITO, Ward-9(5), Pune Sahakari Patsanstha Maryadit Lonavala, Vasantdada Patil Sankul, Lonavala, Pune-410401 vs. PAN : AAAAL 1845 P (Appellant) (Respondent) For Assessee : Shri Pramod S Shingte, CA For Revenue : Shri Uodol Raj Singh, DR Date of Hearing : 13.11.2025 Date of Pronouncement : 18.11.2025 ORDER PER : MANISH BORAD, AM This appeal at the instance of the assessee is directed against the order o…

New Mangalore Port Road Company Limited, New Delhi vs. DCIT, Circle-16(1), Delhi

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 1053/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Nov 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No.1053/Del/2025, A.Y. 2015-16 New Mangalore Port Road Deputy Commissioner Of Company Limited, Income Tax, Circle-16(1), D-21, Corporate Park, Vs. C. R. Building, I P Estate, Sector-21, Dwarka, New Delhi New Delhi Pan: Aabcn9106E (Appellant) (Respondent) Appellant By Ms. Khushboo Singhal, Ca Respondent By Ms. Amisha S. Gupt, Cit(Dr) Date Of Hearing 21/08/2025 Date Of Pronouncement 17/11/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal For Assessment Year (‘Ay’) 2015-16 Filed By The Assessee Is Directed Against The Order Dated 15.09.2022 Of The Commissioner Of Income Tax (Appeals), Nfac, New Delhi [‘Cit(A)’].

Section 271(1)(c)Section 32Section 36(1)(iii)

…it had also filed an affidavit justifying the delay in filing this appeal. Keeping in view decisions of the Hon’ble New Mangalore Port Road Company Ltd. Supreme Court in cases of Collector, Land Acquisition, Anantnag & Anr. Vs Mst. Katiji and others (1987) 2 SCC 107 and N. Balakrishnan Vs M. Krishnamurthy 1998 (7) SCC 123 and the decision of Hon’ble Delhi High Court in the case of HL Malhotra & Company Pvt. Ltd. (ITA No. 211/2020 & CM Appeals 32045-32047/2020 dated 22nd December, 2020), we condone the delay in the interest of justice. 4. The relevant facts giving rise to this appeal are that the assessee, eng…

Anita Gurumukh Gidwani, Sangli vs. ACIT, Circle, Sangli

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 1162/PUN/2025[2017-18]Status: DisposedITAT Pune14 Nov 2025AY 2017-18

Bench: Shri Manish Borad & Shri Vijay Bhamore

For Appellant: NoneFor Respondent: Shri Uodol Raj Singh, DR
Section 144Section 250

…sonable cause which prevented the appellant from filing the appeal within the stipulated time. We, therefore, taking guidance from the judgments of Hon"ble Apex Court in the case of *Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors*. [(1987) 2 SCC 107] and in the case of *Inder Singh Vs. State of Madhya Pradesh* judgment dated 21.03.2025 (2025 INSC 382), condone the delay in filing of the instant appeal before this Tribunal and admit the appeal for adjudcation. - 3. When the case called for, none appeared on behalf of the assessee. In the past also, the assessee failed to appear on the date fix…

Incometax Officer, Ward-1(1), Tiptur vs. Sriudayaravi Credit Co-Op, Tiptur

In the result, appeals of the Revenue are dismissed

ITA 2095/BANG/2024[2018-19]Status: DisposedITAT Bangalore14 Nov 2025AY 2018-19

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 2(24)(viia)Section 80PSection 80P(2)(a)Section 80P(4)

…r delay in filling the appeal is in paras 4 and 5 that he was busy in time barring scrutiny assessment cases. 5. Considering the reasons given by the AO and relying on the judgment in the case of Collector of Land Acquisition Vs. MST Katiji and Others, (1987) 2 SCC 107 : 1987 (2) SC, the delay in filing the appeal is condoned. 6. Briefly stated, the facts of the case are that the assessee filed its return of income and claimed deduction under section 80P(2)(a)(i) of the Act. The case was selected for scrutiny and statutory notices were issued to the assessee. From the documents filed, it was noticed that the asse…

Incometax Officer, Ward-1, Tiptur vs. Sri Udayravi Credit Co-Op, Tiptur

ITA 2094/BANG/2024[2017-18]Status: DisposedITAT Bangalore14 Nov 2025AY 2017-18

Bench: Shri.Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Smt. Harsha J, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 2(24)(viia)Section 80PSection 80P(2)(a)Section 80P(4)

…and 5 that he was busy in time barring scrutiny assessment cases. ITA Nos.2094, 2095/Bang/2024 Page 3 of 16 5. Considering the reasons given by the AO and relying on the judgment in the case of Collector of Land Acquisition Vs. MST Katiji and Others, (1987) 2 SCC 107 : 1987 (2) SC, the delay in filing the appeal is condoned. 6. Briefly stated, the facts of the case are that the assessee filed its return of income and claimed deduction under section 80P(2)(a)(i) of the Act. The case was selected for scrutiny and statutory notices were issued to the assessee. From the documents filed, it was noticed that the ass…

Assistant Commissioner of Income Tax, Delhi vs. Vireet Investments Private Limited, Delhi

In the result, the appeal of Revenue is partly allowed as boave for statistical purpose

ITA 3010/DEL/2024[2007-08]Status: DisposedITAT Delhi14 Nov 2025AY 2007-08

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 10(38)Section 115J

…Officer (‘AO’). 3.1 The Revenue’s appeal is delay by 20 days. Condonation application was duly considered by us. Keeping in view decisions of the Hon’ble Supreme Court in cases of Collector, Land Acquisition, Anantnag & Anr. Vs Mst. Katiji and others (1987) 2 SCC 107 and N. Balakrishnan Vs M. Krishnamurthy 1998 (7) SCC 123 and the decision of Hon’ble Delhi High Court in the case of HL Malhotra & Company Pvt. Ltd. (ITA No. 211/2020 & CM Appeals 32045- 32047/2020 dated 22nd December, 2020), the delay is condoned and the appeal is being decided on merit. Disallowance of claim of exemption under section 10(38) of…

Sujit Vitthal Shinde, Pune vs. ITO Ward 11(1), Pune

In the result, the appeal filed by the asseseee is allowed for statistical purposes

ITA 100/PUN/2025[2021-22]Status: DisposedITAT Pune13 Nov 2025AY 2021-22

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.100/Pun/2025 Assessment Year 2021-22

For Appellant: Smt. Deepa KhareFor Respondent: Shri Vinod Pawar
Section 143(1)Section 143(1)(a)

…easonable cause’ prevented the appellant to file the appeal within the stipulated time. We therefore taking guidance from the judgments of Hon’ble Apex Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) condone the delay of 75 days in filing of the instant appeal before this Tribunal and admit the appeal for adjudication. 3. At the outset, ld. Counsel for the appellant submitted that ld.CIT(A) has dismissed the appeal in limine by not condoning th…

Institute for Multi-Lingual Education (Imli), Pune vs. CIT Exemptions, Pune

In the result, both the appeals filed by the appellant trust are allowed for statistical purposes

ITA 2732/PUN/2024[-]Status: DisposedITAT Pune13 Nov 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Amol Khairnar
Section 12ASection 12A(1)(ac)Section 80G

…filing the appeals with delay, we are of the considered opinion that these are fit cases to condone the delay in light of judgments of Hon’ble Supreme Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382). We therefore condone the delay of 23 days in filing the appeals and admit the appeals for adjudication. ITA No.2732/PUN/2024: 5. Briefly, the facts of the case are that the appellant is a trust, filed application on Form No.10AB under clause (iii…

Institute for Multi-Lingual Education (Imli), Pune vs. CIT Exemption, Pune

In the result, both the appeals filed by the appellant trust are allowed for statistical purposes

ITA 2731/PUN/2024[-]Status: DisposedITAT Pune13 Nov 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: NoneFor Respondent: Shri Amol Khairnar
Section 12ASection 12A(1)(ac)Section 80G

…filing the appeals with delay, we are of the considered opinion that these are fit cases to condone the delay in light of judgments of Hon’ble Supreme Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382). We therefore condone the delay of 23 days in filing the appeals and admit the appeals for adjudication. ITA No.2732/PUN/2024: 5. Briefly, the facts of the case are that the appellant is a trust, filed application on Form No.10AB under clause (iii…

Vibhav Dilip Metha, Ahilyanagar vs. ITO, Wrd-2, Ahilyanagar

In the result, appeal filed by the assessee is allowed

ITA 2074/PUN/2025[2014-15]Status: DisposedITAT Pune12 Nov 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2074/Pun/2025 Assessment Year 2014-15

For Appellant: Shri Prasad BhandariFor Respondent: Shri Vinod Pawar
Section 142(1)Section 271(1)(b)

…and assessee would not have gained from filing the appeal with a delay. We therefore in light of 3 Vaibhav Dilip Mehta judgments of Hon’ble Apex Court Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) condone the delay of 306 days in filing of the instant appeal before this Tribunal. 4. At the outset, Ld. Counsel for the assessee referring to ITA No.2075/PUN/2025 for A.Y. 2015-16 in the assessee’s own case wherein also similar delay in filing of…

Rajrshi Shahu Nagari Sahakari Pat Sanstha Maryadit Kurundwad, Kolhapur vs. Income Tax Officer, Ichalkaranji

In the result, the appeal filed by the asseseee is allowed for statistical purposes

ITA 1955/PUN/2025[AY 2020-21]Status: DisposedITAT Pune12 Nov 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1955/Pun/2025 Assessment Year 2020-21

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Vinod Pawar
Section 143(2)Section 143(3)Section 80P(2)(d)

…easonable cause’ prevented the appellant to file the appeal within the stipulated time. We therefore taking guidance from the judgments of Hon’ble Apex Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) condone the delay of 18 days in filing of the instant appeal before this Tribunal and admit the appeal for adjudication. 3. At the outset, ld. Counsel for the appellant submitted that the issue relates to denial of deduction u/s.80P(2)(d) for the i…

Arjunsinh Madansinh Mohite Patil, Solapur vs. CIT(Appeals), NFAC, Delhi

In the result, all the appeals filed by the two assessee(s) are allowed for statistical purposes

ITA 1624/PUN/2025[2017-18]Status: DisposedITAT Pune12 Nov 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1620 To 1622 & 1624/Pun/2025 Assessment Years : 2014-15, 2015-16, 2016-17 & 2017-18

For Respondent: Shri Amol Khairnar
Section 147Section 250(6)

…would not have gained from filing the appeals with a delay. We therefore adopting a justice oriented approach and in light of judgments of Hon’ble Apex Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) condone the respective delay in filing of the instant appeals by both the assessee(s) before this Tribunal and admit the appeals for adjudication. 5. When the case called for none appeared on behalf of the assessee(s) despite due service of notice…

Nandinidevi Vijaysinh Mohite Patil, Solapur vs. CIT (A), NFAC, Delhi

In the result, all the appeals filed by the two assessee(s) are allowed for statistical purposes

ITA 1623/PUN/2025[2015-2016]Status: DisposedITAT Pune12 Nov 2025AY 2015-2016

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1620 To 1622 & 1624/Pun/2025 Assessment Years : 2014-15, 2015-16, 2016-17 & 2017-18

For Respondent: Shri Amol Khairnar
Section 147Section 250(6)

…would not have gained from filing the appeals with a delay. We therefore adopting a justice oriented approach and in light of judgments of Hon’ble Apex Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) condone the respective delay in filing of the instant appeals by both the assessee(s) before this Tribunal and admit the appeals for adjudication. 5. When the case called for none appeared on behalf of the assessee(s) despite due service of notice…

Arjunsinh Madansinh Mohite Patil, Solapur vs. CIT(Appeals), NFAC, Delhi

In the result, all the appeals filed by the two assessee(s) are allowed for statistical purposes

ITA 1622/PUN/2025[2016-17]Status: DisposedITAT Pune12 Nov 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1620 To 1622 & 1624/Pun/2025 Assessment Years : 2014-15, 2015-16, 2016-17 & 2017-18

For Respondent: Shri Amol Khairnar
Section 147Section 250(6)

…would not have gained from filing the appeals with a delay. We therefore adopting a justice oriented approach and in light of judgments of Hon’ble Apex Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) condone the respective delay in filing of the instant appeals by both the assessee(s) before this Tribunal and admit the appeals for adjudication. 5. When the case called for none appeared on behalf of the assessee(s) despite due service of notice…

Arjunsinh Madansinh Mohite Patil, Solapur vs. CIT(Appeals), NFAC, Delhi

In the result, all the appeals filed by the two assessee(s) are allowed for statistical purposes

ITA 1621/PUN/2025[2015-16]Status: DisposedITAT Pune12 Nov 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1620 To 1622 & 1624/Pun/2025 Assessment Years : 2014-15, 2015-16, 2016-17 & 2017-18

For Respondent: Shri Amol Khairnar
Section 147Section 250(6)

…would not have gained from filing the appeals with a delay. We therefore adopting a justice oriented approach and in light of judgments of Hon’ble Apex Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) condone the respective delay in filing of the instant appeals by both the assessee(s) before this Tribunal and admit the appeals for adjudication. 5. When the case called for none appeared on behalf of the assessee(s) despite due service of notice…

Arjunsinh Madansinh Mohite Patil, Solapur vs. CIT(Appeals) NFAC, Delhi

In the result, all the appeals filed by the two assessee(s) are allowed for statistical purposes

ITA 1620/PUN/2025[2014-15]Status: DisposedITAT Pune12 Nov 2025AY 2014-15

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1620 To 1622 & 1624/Pun/2025 Assessment Years : 2014-15, 2015-16, 2016-17 & 2017-18

For Respondent: Shri Amol Khairnar
Section 147Section 250(6)

…would not have gained from filing the appeals with a delay. We therefore adopting a justice oriented approach and in light of judgments of Hon’ble Apex Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) condone the respective delay in filing of the instant appeals by both the assessee(s) before this Tribunal and admit the appeals for adjudication. 5. When the case called for none appeared on behalf of the assessee(s) despite due service of notice…

Rekha Ajit Chaudhari, Pune vs. Ward 3(3), Pune

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2069/PUN/2025[2013-14]Status: DisposedITAT Pune10 Nov 2025AY 2013-14

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2069/Pun/2025 Assessment Year 2013-14

For Appellant: NoneFor Respondent: Shri Vinod Pawar
Section 142(1)Section 144Section 147Section 148Section 69

…lay is not intentional and assessee would not have gained from filing the appeal with a delay. We therefore in light of judgments of Hon’ble Apex Court Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) condone the delay of 125 days in filing of the instant appeal before this Tribunal. 5. We have heard the ld. Departmental Representative and perused the record placed before us. We observe that the 3 Rekha Ajit Chaudhari assessee is an individual…

Sarfaraz Salim Kacchi, Sangli vs. Income Tax Officer, Sangli

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1935/PUN/2025[2015-2016]Status: DisposedITAT Pune10 Nov 2025AY 2015-2016

Bench: Dr.Manish Borad

For Appellant: NoneFor Respondent: Shri Ajitesh Meena
Section 147Section 249(4)Section 250(6)Section 69

…ot have gained from filing the appeal with a delay. I therefore taking justice oriented approach and taking guidance from the judgments of Hon’ble Apex Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) condone the delay of 500 days in filing of the instant appeal before this Tribunal and admit the appeal for adjudication. 4. When the case called for, none appeared on behalf of the assessee despite due service of notice of hearing. Even on the pre…

Manoj Suresh Tatooskar, Pune vs. Circle 1(1), Pune

In the result, the appeal filed by the assessee is allowed

ITA 1729/PUN/2025[2018-19]Status: DisposedITAT Pune04 Nov 2025AY 2018-19

Bench: Dr.Manish Borad

For Appellant: Shri Nikhil S PathakFor Respondent: Shri R.Y. Balawade
Section 142(1)Section 143(2)Section 143(3)

…ee to file the appeal within the stipulated time. I therefore adopting justice oriented approach and taking guidance from the judgments of Hon’ble Apex Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) I condone the delay of 166 days in filing of the instant appeal before this Tribunal and admit the appeal for adjudication. 3. The only issue raised by the assessee is that ld.CIT(A) erred in confirming the addition towards notional rent income at…

Sunil Kumar Bhilare, Satara vs. Income Tax Officer, WD-3, Satara

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2014/PUN/2025[2020-21]Status: DisposedITAT Pune03 Nov 2025AY 2020-21

Bench: Dr.Manish Borad

For Appellant: Shri Sunil PorwalFor Respondent: Shri Ajitesh Meena
Section 10Section 143(1)

…o file the appeal. However, in the larger interest of justice adopting justice oriented approach and taking guidance from the judgments of Hon’ble Apex Court in the case of Collector, Land Acquisition, Anantnag & Anr. Vs. Mst. Katiji & Ors. reported in (1987) 2 SCC 107 and in the case of Inder Singh Vs. State of Madhya Pradesh judgment dated 21.03.2025 (2025 INSC 382) I condone the delay of 938 days in filing of the instant appeal before this Tribunal and admit the appeal for adjudication. 4. The only grievance of the assessee is that ld.CIT(A) erred in confirming the action of Central Processing Cell of 3 Sunil…