Surinder Kumar Boveja v. CWT

287 ITR 52High Court2006#5851 most cited
20

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Sections most often in play

Section 270ASection 270A(1)(d)Section 270A(d)Section 143(3)Section 249(2)Section 249(3)Section 272A(1)(d)Section 69A

Issues it is cited on

public servantprincipal officersection 272a(1)(d)section 200asection 234esection 249section 234section 23section 270areasonable causecondonation of delaysection 24

Judgments citing Surinder Kumar Boveja v. CWT

NOBEL BIOCARE INDIA PRIVATE LIMITED ,MUMBAI vs. ACIT, 15(2)(1), MUMBAI

ITA 6881/MUM/2025[2020-21]Status: DisposedITAT Mumbai09 Feb 2026AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Hinal Shah &For Respondent: Mr. Leyaqat Ali Aafaqui, Sr. DR

…s together on months together on their tables. 5.5 The Hon'ble Delhi High Court in its decision in the case 5.5 The Hon'ble Delhi High Court in its decision in the case 5.5 The Hon'ble Delhi High Court in its decision in the case Surinder Kumar Boveja Vs. CWT 287 ITR 52 has Surinder Kumar Boveja Vs. CWT 287 ITR 52 has Surinder Kumar Boveja Vs. CWT 287 ITR 52 has categorically held that delays cannot be routinely excused. In categorically held that delays cannot be routinely excused. In categorically held that delays cannot be routinely excused. In this decision, the Hon'ble High Court has further held as this dec…

NOBEL BIOCARE INDIA PRIVATE LIMITED ,MUMBAI vs. ACIT, CIRCLE 15(2)(1), MUMBAI

ITA 6880/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Hinal Shah &For Respondent: Mr. Leyaqat Ali Aafaqui, Sr. DR

…s together on months together on their tables. 5.5 The Hon'ble Delhi High Court in its decision in the case 5.5 The Hon'ble Delhi High Court in its decision in the case 5.5 The Hon'ble Delhi High Court in its decision in the case Surinder Kumar Boveja Vs. CWT 287 ITR 52 has Surinder Kumar Boveja Vs. CWT 287 ITR 52 has Surinder Kumar Boveja Vs. CWT 287 ITR 52 has categorically held that delays cannot be routinely excused. In categorically held that delays cannot be routinely excused. In categorically held that delays cannot be routinely excused. In this decision, the Hon'ble High Court has further held as this dec…

RAJEEV CHAUHAN,GADIWAN MAINPURI vs. ITO WARD2(4)5 MAINPURI, KACHEHARI ROAD MAINPURI

In the result, appeals filed by the assessee are allowed for

ITA 438/AGR/2025[2017-2018]Status: DisposedITAT Agra24 Dec 2025AY 2017-2018

Bench: : Shri S. Rifaur Rahman

Section 115BSection 143(2)Section 143(3)Section 271ASection 69A

…is substantial. Same cannot be condoned. In this regard he relied on the decision in the case of RB Ramlingam Petitioner vs RB Shavaneshwari (2009)(SC2)GJX 106 (SC), CIT vs. Ram Mohan Kabra (2002) 257 ITR 773 (P&H) and Surinder Kumar Boveja vs. CWT (2006) 287 ITR 52 (Del). 8. Considered rival submissions and material placed on record. 9. After considering the facts available on record, I observe that the reasonable cause for not filing the appeal before CIT(A) within time is submitted before me in the form of affidavit and further it is brought to my notice that the assessment notices were issued on wrong…

RAJEEV CHAUHAN,GADIWAN MAINPURI vs. ITO WARD 2(2)5 MAINPURI, MAINPURI

In the result, appeals filed by the assessee are allowed for

ITA 437/AGR/2025[2017-2018]Status: DisposedITAT Agra24 Dec 2025AY 2017-2018

Bench: : Shri S. Rifaur Rahman

Section 115BSection 143(2)Section 143(3)Section 271ASection 69A

…is substantial. Same cannot be condoned. In this regard he relied on the decision in the case of RB Ramlingam Petitioner vs RB Shavaneshwari (2009)(SC2)GJX 106 (SC), CIT vs. Ram Mohan Kabra (2002) 257 ITR 773 (P&H) and Surinder Kumar Boveja vs. CWT (2006) 287 ITR 52 (Del). 8. Considered rival submissions and material placed on record. 9. After considering the facts available on record, I observe that the reasonable cause for not filing the appeal before CIT(A) within time is submitted before me in the form of affidavit and further it is brought to my notice that the assessment notices were issued on wrong…

ATTIVO PROTEZIONE PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER WARD-22(1)(1), LALBAUG

ITA 5380/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosainattivo Protezione Pvt Ltd Vs. Ito, Ward – 22(1)(1) 108, 1St Floor Ashar Enclave Room No. 319, Piramal Kolshet Road, Thane – 400 Chambers, Mumbai 607. Pan/Gir No. Aalca4330M (Applicant) (Respondent)

Section 250Section 5

…IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH MUMBAI BEFORE HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER Attivo Protezione Pvt Ltd Vs. ITO, Ward – 22(1)(1) 108, 1st Floor Ashar Enclave Room No. 319, Piramal Kolshet Road, Thane – 400 Chambers, Mumbai 607. PAN/GIR No. AALCA4330M (Applicant) (Respondent) Assessee by None Revenue by Shri Rajesh Sakhardane, Sr. DR Date of Hearing 27.10.2025 Date of Pronouncement 31.10.2025 आदेश / ORDER PER SANDEEP GOSAIN, JM: The present appeal has been filed by the assessee challenging the impugned order dt. 29.09.2021 passed under section 250 of the Income Tax Act, 1961 (‘th…

ESSCON INTEGRATED SECURITY SOLUTIONS PRIVATE LIMITED ,DELHI vs. ITO, WARD-8(1), DELHI

In the result, appeals in ITA

ITA 369/DEL/2025[2020-21]Status: DisposedITAT Delhi31 Jul 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 270ASection 272A(1)(d)

…ut to condone the delay as there was inordinate delay in filing the Appeals before the Ld. CIT(A). The Ld. Department's Representative has also relied on the Judgment of Jurisdictional High Court in the case of Surinder Kumar Boveja Vs. CWT (2006) reported in 287 ITR 52 (Del) and submitted that the Ld. CIT(A) has rightly dismissed the Appeals on delay in latches. 4.We have heard both the parties and perused the material available on record on the issue of delay in filing the present Appeal. The Assessee preferred three Appeals aggrieved by the orders of penalty imposed u/s 272A(1)(d), 272A(1)(d) and 270A of the…

ESSCON INTEGRATED SECURITY SOLUTIONS PRIVATE LIMITED,DELHI vs. ITO,WARD-8(1), DELHI

In the result, appeals in ITA

ITA 368/DEL/2025[2020-21]Status: DisposedITAT Delhi31 Jul 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 270ASection 272A(1)(d)

…ut to condone the delay as there was inordinate delay in filing the Appeals before the Ld. CIT(A). The Ld. Department's Representative has also relied on the Judgment of Jurisdictional High Court in the case of Surinder Kumar Boveja Vs. CWT (2006) reported in 287 ITR 52 (Del) and submitted that the Ld. CIT(A) has rightly dismissed the Appeals on delay in latches. 4.We have heard both the parties and perused the material available on record on the issue of delay in filing the present Appeal. The Assessee preferred three Appeals aggrieved by the orders of penalty imposed u/s 272A(1)(d), 272A(1)(d) and 270A of the…

ESSCON INTEGRATED SECURITY SOLUTIONS PRIVATE LIMITED,DELHI vs. ITO,WARD-8(1), DELHI

In the result, appeals in ITA

ITA 367/DEL/2025[2020-21]Status: DisposedITAT Delhi31 Jul 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 270ASection 272A(1)(d)

…ut to condone the delay as there was inordinate delay in filing the Appeals before the Ld. CIT(A). The Ld. Department's Representative has also relied on the Judgment of Jurisdictional High Court in the case of Surinder Kumar Boveja Vs. CWT (2006) reported in 287 ITR 52 (Del) and submitted that the Ld. CIT(A) has rightly dismissed the Appeals on delay in latches. 4.We have heard both the parties and perused the material available on record on the issue of delay in filing the present Appeal. The Assessee preferred three Appeals aggrieved by the orders of penalty imposed u/s 272A(1)(d), 272A(1)(d) and 270A of the…

ADITYA SAPRU ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 9(3)(2), MUMBAI

In the result, the appeal is dismissed on account of delay

ITA 1421/MUM/2025[2013-14]Status: DisposedITAT Mumbai24 Jun 2025AY 2013-14
For Appellant: \nShri Satish Mody & Shri Dhiren Talati,ARFor Respondent: \nShri Aditya Rai (Sr. DR)
Section 143(3)Section 154Section 54

…r expected nor can it be a\nnormal conduct of a public servant or a litigant that they would keep the files\nunmoved, unprocessed for months together on their tables.\n5.5 The Hon'ble Delhi High Court in its decision in the case\nSurinder Kumar Boveja Vs. CWT 287 ITR 52 has categorically\nheld that delays cannot be routinely excused. In this decision, the\nHon'ble High Court has further held as under:\n\"Where the delay is prolonged and the assessee is not able to show that the delay had\noccurred in spite of exercise of due attention and diligence, the assessee cannot\ncomplain, if the delay is not condoned.\"\n…

PRAFULBHAI JAGUBHAI PATEL,SURAT vs. ITO, WARD-1, BARDOLI

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

ITA 1294/SRT/2024[2013-14]Status: DisposedITAT Surat20 May 2025AY 2013-14

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1294/Srt/2024 Assessment Year: (2013-14) (Hybrid Hearing) Prafulbhai Jagubhai Patel, Vs. Ito, 2/7, Dastan, Palsana, Surat – Ward - 1, 394 310 Bardoli "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bvopp8701K (Appellant) (Respondent) Appellant By Shri Shrijignesh Parikh, Ar With Shri Marufkhan Pathan, Ar Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 12/03/2025 Date Of Pronouncement 20/05/2025

Section 144Section 147Section 148Section 148ASection 250Section 69A

…relied upon the decisions in cases of B. R. Ramalingam vs. R. B. Bhavaneshwari, (2009) (SC2) GJX 106 (SC), CIT vs. Ram Mohan Kabra, (2002) 257 ITR 773 (P&H) and Surinder Kumar Boveja vs. ITA No.1294/SRT/2024/AY.2013-14 Prafulbhai Jagabhai Patel CWT, (2006) 287 ITR 52 (Del) and held that the appellant had not made a case for having “sufficient cause” for delay in filing appeal. The appeal filed by the appellant was held to be invalid and non-maintainable, being out of time. He, therefore, did not admit the appeal and dismissed the same. 5. Aggrieved by the order of CIT(A) the assessee has filed present appeal b…

NEW HIGHER SECONDARY SCHOOL,TRIVANDRUM vs. DCIT, TRIVANDRUM

In the result, the appeals by the assessee are dismissed

ITA 55/COCH/2023[2015-16 QUARTER 4]Status: HeardITAT Cochin28 Aug 2023

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Sreeram Sekar, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200ASection 234E

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Sanjay Arora, Accountant Member and Shri Manomohan Das, Judicial Member ITA Nos. 52-55/ Coch/2023 (Assessment Year: 2015-16) New Higher Secondary School The Deputy Comissioner Kanjiramkulam S.O. of Income Tax Athiyannur (Part) Thiruvananthapuram vs. Thiruvananthapuram 695524 [PAN:TVDNO 0608G] (Appellant) (Respondent) Appellant by: Shri Sreeram Sekar, CA Respondent by: Smt. J.M. Jamuna Devi, Sr. D.R. Date of Hearing: 13.07.2023 Date of Pronouncement: 28.08.2023 O R D E R Per Bench This is a set of four Appeals by the Assessee, an educational i…

NEW HIGHER SECONDARY SCHOOL ,TRIVANDRUM vs. DCIT , TRIVANDRUM

In the result, the appeals by the assessee are dismissed

ITA 54/COCH/2023[2015-16 (Qurt-3)]Status: DisposedITAT Cochin28 Aug 2023

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Sreeram Sekar, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200ASection 234E

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Sanjay Arora, Accountant Member and Shri Manomohan Das, Judicial Member ITA Nos. 52-55/ Coch/2023 (Assessment Year: 2015-16) New Higher Secondary School The Deputy Comissioner Kanjiramkulam S.O. of Income Tax Athiyannur (Part) Thiruvananthapuram vs. Thiruvananthapuram 695524 [PAN:TVDNO 0608G] (Appellant) (Respondent) Appellant by: Shri Sreeram Sekar, CA Respondent by: Smt. J.M. Jamuna Devi, Sr. D.R. Date of Hearing: 13.07.2023 Date of Pronouncement: 28.08.2023 O R D E R Per Bench This is a set of four Appeals by the Assessee, an educational i…

NEW HIGHER SECONDARY SCHOOL ,TRIVANDRUM vs. DCIT , TRIVANDRUM

In the result, the appeals by the assessee are dismissed

ITA 53/COCH/2023[2015-16 QTR 2]Status: DisposedITAT Cochin28 Aug 2023

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Sreeram Sekar, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200ASection 234E

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Sanjay Arora, Accountant Member and Shri Manomohan Das, Judicial Member ITA Nos. 52-55/ Coch/2023 (Assessment Year: 2015-16) New Higher Secondary School The Deputy Comissioner Kanjiramkulam S.O. of Income Tax Athiyannur (Part) Thiruvananthapuram vs. Thiruvananthapuram 695524 [PAN:TVDNO 0608G] (Appellant) (Respondent) Appellant by: Shri Sreeram Sekar, CA Respondent by: Smt. J.M. Jamuna Devi, Sr. D.R. Date of Hearing: 13.07.2023 Date of Pronouncement: 28.08.2023 O R D E R Per Bench This is a set of four Appeals by the Assessee, an educational i…

NEW HIGHER SECONDARY SCHOOL,TRIVANDRUM vs. DCIT, TRIVANDRUM

In the result, the appeals by the assessee are dismissed

ITA 52/COCH/2023[2015-16 (QT1)]Status: DisposedITAT Cochin28 Aug 2023

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Shri Sreeram Sekar, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 200ASection 234E

…IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Sanjay Arora, Accountant Member and Shri Manomohan Das, Judicial Member ITA Nos. 52-55/ Coch/2023 (Assessment Year: 2015-16) New Higher Secondary School The Deputy Comissioner Kanjiramkulam S.O. of Income Tax Athiyannur (Part) Thiruvananthapuram vs. Thiruvananthapuram 695524 [PAN:TVDNO 0608G] (Appellant) (Respondent) Appellant by: Shri Sreeram Sekar, CA Respondent by: Smt. J.M. Jamuna Devi, Sr. D.R. Date of Hearing: 13.07.2023 Date of Pronouncement: 28.08.2023 O R D E R Per Bench This is a set of four Appeals by the Assessee, an educational i…

ACIT, NEW DELHI vs. M/S. CONTAINER CORPORATION OF INDIA LTD., NEW DELHI

In the result ITA No. 1364/Del/2012 for AY 2007-08 filed by the revenue is dismissed

ITA 1364/DEL/2012[2007-08]Status: DisposedITAT Delhi23 Feb 2018AY 2007-08

Bench: Shri Kuldip Singh & Shri Prashant Maharishi

For Appellant: Shri Kirshnan, AdvFor Respondent: Ms. Rachna Singh, CIT DR

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B ”: NEW DELHI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER ITA No. 1555/Del/2012 and 1363/Del/2012 (Assessment Year: 2006-07) ACIT, Vs. Container Cooperation of India Ltd, Circle-3(1), C-3, CONCOR Bhawan, Opp Apollo New Delhi Hospital, Mathura Road, New Delhi PAN:AAACC1205A (Appellant) (Respondent) Container Cooperation of India Ltd, Vs. ACIT, C-3, CONCOR Bhawan, Opp Apollo Circle-3(1), Hospital, Mathura Road, New Delhi New Delhi PAN:AAACC1205A (Appellant) (Respondent) ACIT, Container Cooperation of India Ltd, Vs. Circle-3(1)…

ATMA RAM AUTO ENTERPRISES,AGRA vs. ACIT(TDS),, AGRA

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 6/AGR/2016[2011-12]Status: DisposedITAT Agra26 Sept 2017AY 2011-12

Bench: : Shri A.D. Jain & Shri Dr. Mitha Lal Meena

Section 194CSection 194HSection 271

…lf shown them as commission and deducted TDS on some of such payments treating the same as commission paid in his books of accounts. 3. Ld. CIT(A) has confirmed the appeal interalia observing as under: “It is held in the case of Surendra Boveja Vs CWT (2006) 287 ITR 52 (Delhi High Court) that want of due care, ignorance of law or failure to seek legal advice are not sufficient grounds for condonation of delay. Similar view has been taken by the Hon'ble Madras High Court in Madhu Dadha Vs ACIT (2009) 317 ITR 458 (Madras). A third member decision of the Tribunal in JCIT Vs TFE Ltd. (2007) 104 ITD 149 (Chennai) (TM…

PUSHPA M KHONA,MUMBAI vs. ITO 20(2)(3), MUMBAI

In the result, the appeals filed by the assessee’s for Asst

ITA 6391/MUM/2016[2006-07]Status: DisposedITAT Mumbai22 Feb 2017AY 2006-07

Bench: Shri Rajendra, Am & Shri Ram Lal Negi, Jm आयकर अपील सं./Ita No.6390/Mum/2016 ("नधा"रण वष" / Assessment Year: 2009-10) Mr. Dushyant M. Khona. Vs. The Ito, 20(2)(1), M/S. Vss & Associates, Mumbai. Chartered Accountants, 306, Dalamal Chambers, New Marine Lines, Mumbai- 400 020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacpk4146M .. (""यथ" / Respondent) (अपीलाथ" /Appellant) & आयकर अपील सं./Ita No.6391/Mum/2016 ("नधा"रण वष" / Assessment Year: 2006-07) Mrs. Pushpa M. Khona. Vs. The Ito, 20(2)(3), M/S. Vss & Associates, Mumbai. Chartered Accountants, 306, Dalamal Chambers, New Marine Lines, Mumbai- 400 020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aarpk6482H .. (""यथ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Shri. Prakash Jhunjhunwala & Sanjay JainFor Respondent: Shri. M.C. Omi Ningshen
Section 143(3)

…assessment order the assessee filed the appeal against the said order. However, the appeal was filed after the expiry of limitation period. The Ld. CIT(A) relying on the decision of Hon’ble Delhi High Court passed in the case of Surinder Kumar Boveja vs. CWT 287 ITR 52 and decision of Hon’ble Supreme Court in the case of Rankak and others vs. Rewa Coalfields Ltd. reported at AIR 1962 SC 361, dismissed the application for condonation of delay submitted by the assessee and dismissed the appeal in limine. The assessee is in appeal before the tribunal against impugned order passed by the Ld. CIT(A) on the following…

DUSHYANT M KHONA,MUMBAI vs. ITO 20(2)(1), MUMBAI

In the result, the appeals filed by the assessee’s for Asst

ITA 6390/MUM/2016[2009-10]Status: DisposedITAT Mumbai22 Feb 2017AY 2009-10

Bench: Shri Rajendra, Am & Shri Ram Lal Negi, Jm आयकर अपील सं./Ita No.6390/Mum/2016 ("नधा"रण वष" / Assessment Year: 2009-10) Mr. Dushyant M. Khona. Vs. The Ito, 20(2)(1), M/S. Vss & Associates, Mumbai. Chartered Accountants, 306, Dalamal Chambers, New Marine Lines, Mumbai- 400 020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacpk4146M .. (""यथ" / Respondent) (अपीलाथ" /Appellant) & आयकर अपील सं./Ita No.6391/Mum/2016 ("नधा"रण वष" / Assessment Year: 2006-07) Mrs. Pushpa M. Khona. Vs. The Ito, 20(2)(3), M/S. Vss & Associates, Mumbai. Chartered Accountants, 306, Dalamal Chambers, New Marine Lines, Mumbai- 400 020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aarpk6482H .. (""यथ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Shri. Prakash Jhunjhunwala & Sanjay JainFor Respondent: Shri. M.C. Omi Ningshen
Section 143(3)

…assessment order the assessee filed the appeal against the said order. However, the appeal was filed after the expiry of limitation period. The Ld. CIT(A) relying on the decision of Hon’ble Delhi High Court passed in the case of Surinder Kumar Boveja vs. CWT 287 ITR 52 and decision of Hon’ble Supreme Court in the case of Rankak and others vs. Rewa Coalfields Ltd. reported at AIR 1962 SC 361, dismissed the application for condonation of delay submitted by the assessee and dismissed the appeal in limine. The assessee is in appeal before the tribunal against impugned order passed by the Ld. CIT(A) on the following…

M/S SPPORTHI SADAN CONVENT vs. THE COMMISSIONER OF INCOME TAX

Accordingly, the appeal fails and stands dismissed

ITA/100066/2015HC Karnataka17 Feb 2016

Bench: The Itat. The Said Appeal Was Presented With The Delay Of 997 Days. The Tribunal On

Section 11Section 12ASection 260A

…t submitting that the Assessee was not aware of the law, he could not explain the reason for the delay occurred in filing the appeal”. 4. After recording the aforementioned finding and adverting to the judgement in the case of Surinder Kumar Boveja Vs. CWT, 287 ITR 52 (Delhi), the tribunal dismissed the appeal as having been barred by limitation. 5. A careful perusal of the findings recorded by the Tribunal clearly points to the fact that the delay was sought to be explained on two grounds. Firstly, that the trust was under the bonafide impression that such a registration was not condition precedent for seek…

M/S SEVA SADAN CONVENT vs. THE COMMISSIONER OF

Accordingly, the appeal fails and stands dismissed

ITA/100065/2015HC Karnataka17 Feb 2016

Bench: The Itat. The Said Appeal Was Presented With The Delay Of 997 Days. The Tribunal On

Section 11Section 12ASection 260A

…ept submitting that the Assessee was not aware of the law, he could not explain the reason for the delay occurred in filing the appeal”. 4. After recording the aforementioned finding and adverting to the judgement in the case of Surinder Kumar Boveja Vs. CWT, 287 ITR 52 (Delhi), the tribunal dismissed the appeal as having been barred by limitation. 5. A careful perusal of the findings recorded by the Tribunal clearly points to the fact that the delay was sought to be explained on two grounds. Firstly, that the trust was under the bonafide impression that such a registration was not condition precedent for seekin…