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“reasonable cause”

PenaltySection 273BSection 273B7,285 judgments

The decision most relied on for reasonable cause is Ashok Pai v. CIT (292 ITR 11), cited in 812 judgments on BharatTax.

Leading authorities on reasonable cause

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors.
2 SCC 107 · 1987 · Supreme Court
451
citing judgments

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.

Balakrishnan v. M. Krishnamurthy
7 SCC 123 · 1998 · Supreme Court
368
citing judgments

The Supreme Court outlines the principles for condoning delay in filing appeals, stating that a litigant's lapse is not always a bar if the explanation is bona fide and not a dilatory strategy. Courts should show utmost consideration to suitors and prioritize substantial justice unless the delay is deliberately to gain time.

Akhil Bhartiya Prathmik Shikshak Sangh Bhawan Trust v. ADIT
115 TTJ 419 · 2008 · ITAT
292
citing judgments

Penalty under Section 272A(1)(d) for non-compliance with a notice issued under Section 142(1) is not leviable when the assessee demonstrates a reasonable cause for such non-compliance. The decision defines what constitutes 'reasonable cause' in this context.

Sreenivas Charitable Trust v. Dy. CIT
280 ITR 357 · 2006 · High Court
182
citing judgments

The expression "sufficient cause" for condoning delay in filing appeals must receive a liberal and purposive construction. This approach aims to advance substantial justice, which is of paramount importance.

CIT v. K.S.P. Shanmugavel Nadai and Ors.
153 ITR 596 · 1985 · High Court
171
citing judgments

Where a reasonable cause for delay in filing an appeal exists, the period of delay may not be a relevant factor for condonation. The court has condoned even substantial delays, such as nearly 21 years, based on the presence of a reasonable cause.

People Education and Economic Development Society (PEEDS) v. ITO
100 ITD 87 · 2006 · ITAT
121
citing judgments

When substantial justice and procedural technicalities are in conflict, especially in cases involving non-deliberate delay, the cause of substantial justice must be prioritized. The opposing party cannot claim a vested right to benefit from injustice due to such delays.

Commissioner of Income Tax v. Noida Toll Bridge Co. Ltd.
262 ITR 260 · 2003 · High Court
121
citing judgments

Journal entries for accepting or repaying loans and deposits, without any actual cash transaction, do not violate the provisions of Section 269SS or Section 269T of the Income Tax Act. Consequently, such transactions do not attract penalties under Section 271D or Section 271E.

Judgments citing reasonable cause

Sanjay Ganpat Aher, Nashik vs. Income Tax Officer, Ward-2(1), Nashik

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1627/PUN/2024[2016-17]Status: DisposedITAT Pune24 Oct 2024AY 2016-17

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Smt. Deepa KhareFor Respondent: Shri Arvind Desai, Addl. CIT, DR
Section 142(1)Section 144Section 148Section 270ASection 271(1)(c)

days in filing of the appeals before him for all the three assessment years on the ground that the assessee could not explain any reasonable cause to his satisfaction for the delay in filing of the appeals. We find that in quantum proceedings, the Tribunal condoned the delay

Prathamika Krushi Pathina Sahakara Sangha Niyamitha Nelaji, Kodagu vs. Income Tax Officer, Ward-1, Madikeri

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

ITA 1865/BANG/2024[2021-22]Status: DisposedITAT Bangalore24 Oct 2024AY 2021-22

Bench: Shri George George K & Shri Chandra Poojariassessment Year : 2021-22 M/S. Prathamika Krushi Pathina Sahakara Vs. Ito, Sangha Niyamitha Nelaji, Ward – 1, No.2776, Nelaji, Nelaji Madikeri, Madikeri. Kodagu – 571 214. Pan : Aagan 1004 N Appellant Respondent Assessee By : Ms. Lakshmi, Advocate Revenue By : Shri. Ganesh R Gale, Standing Counsel For Department. Date Of Hearing : 24.10.2024 Date Of Pronouncement : 28.10.2024

For Appellant: Ms. Lakshmi, AdvocateFor Respondent: Shri. Ganesh R Gale, Standing Counsel for Department
Section 143(2)Section 143(3)Section 250Section 80(2)(d)Section 80PSection 80P(2)(a)Section 80P(2)(d)

reasons stated in the application for condonation of delay for belated filing of this appeal and I am of the view that there is reasonable cause and no latches can be attributed to the assessee for belated Page 2 of 8 filing of this appeal. Hence, I condone the delay

Indian Redcross Society Anand District Branch, Anand vs. The Income Tax Officer, Ward-Exemption, Vadodara

In the result, the appeal of the assessee is allowed

ITA 697/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad23 Oct 2024AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Ms. Kaushani Shah, A.RFor Respondent: Shri Sanjay Kumar, Sr. D.R
Section 11Section 119(2)(b)Section 12A

within due date i.e. under section 139(1), since audit was completed well before due date fixed for filingForm10B and assessee had provided a reasonable cause of lapse on part of auditors in filingForm10B, Commissioner (Appeals) was supposed to take into consideration that non-filing of audit report along with

Shree Saibaba Exim Private Limited, Vadodara vs. The Income Tax Officer, Ward-2(1)(3), Vadodara

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

ITA 1312/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad23 Oct 2024AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Darshan Belani, A.RFor Respondent: Shri Sanjay Kumar, Sr. D.R
Section 68

learned C1T(A) erred in law and on facts in deciding the appeal ex-parte. It is submitted that the Appellant had genuine and reasonable cause for not being able to file written submissions before the learned CIT(A), and therefore, the order passed by the learned

Chandan Hassanand Lokwani, Nashik vs. ACIT Circle 1, Nashik

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

ITA 1358/PUN/2024[2012-13]Status: DisposedITAT Pune23 Oct 2024AY 2012-13

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1358/Pun/2024 िनधा"रण वष" / Assessment Year : 2012-13 Chandan Hassanand Lokwani, V The Assistant 2 Jawahar Market, Nashik Road, S Commissioner Of Maharashtra – 422101. Income Tax, Circle-1, Pan : Abcpl7072N Nashik. Appellant / Assessee Respondent / Revenue Assessee By Shri Sanket M Joshi – Ar Revenue By Shri Ramnath P Murkunde - Dr Date Of Hearing 23/10/2024 Date Of Pronouncement 23/10/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Under Section 250 Of The Income Tax Act 1961, Dated 18.05.2024. The Assessee Has Raised The Following Grounds Of Appeal : “1) The Learned Cit(A) Erred In Dismissing The Appeal In Limine By Refusing To Condone The Delay Of 108 Days In Filing The Appeal Without Appreciating That The Said Delay Was Due To Reasonable Cause & The Said Delay Ought To Have Been Condoned In The Interest Of Justice. 2) The Learned Cit(A) Failed To Appreciate That In This Case, The Disallowance U/S 40(A)(Ia) Was Made By The A.O. Towards Non Deduction Of Tds On Interest Paid To Three Nbfc In Spite Of The Fact That The Appellant Had Furnished Ca Certificate In Form 26A To Prove That The Payees Had Offered The Interest To Tax & Paid Taxes Thereon & Hence, The Said Addition Resulted Into Double Taxation Of The Same Income & Therefore, The Impugned Delay Of 108 Days In Filing Appeal Ought To Have Been Condoned In View Of The Ratio Laid Down By Hon'Ble Madras High Court In Case Of Venkatadri Traders Ltd. V. Cit [248 Itr 681].

Section 148Section 194ASection 250Section 40

limine by refusing to condone the delay of 108 days in filing the appeal without appreciating that the said delay was due to reasonable cause and the said delay ought to have been condoned in the interest of justice. 2) The learned CIT(A) failed to appreciate that in this

Baban Rajaram Shahane, Nashik vs. ITO, Ward 3(1), Nashik

ITA 1357/PUN/2024[2017-18]Status: DisposedITAT Pune23 Oct 2024AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1357/Pun/2024 िनधा"रण वष" / Assessment Year : 2017-18 Baban Rajaram Shahane, V The Income Tax Officer, Shop No.3, Saraf Bazar, S Ward-3(1), Nashik. Govind Complex, Nashik Road, Nashik – 422101. Pan: Aswps1504M Appellant / Assessee Respondent / Revenue Assessee By Shri Sanket M Joshi – Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 22/10/2024 Date Of Pronouncement 23/10/2024

Section 144Section 250Section 50C

looking after the income tax asst, work had been diagnosed with mouth cancer and he subsequently succumbed to cancer and therefore, there was a reasonable cause due to which the stamp valuation of land could not be challenged before the A.O. in the asst, u/s 144 but when the said

Syndicate Retired Employees and Other Mutually Aided Coop Credit Society Ltd, Kurnool vs. Income Tax Officer, Ward-1, Kurnool

ITA 172/HYD/2024[2017-18]Status: DisposedITAT Hyderabad23 Oct 2024AY 2017-18

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Madan Mohan Meena, SR-DR
Section 143(3)Section 269SSection 269TSection 271D

prohibition to do so. The assessee pleaded before the Ld. JCIT and the Ld. CIT(A) that for its default there existed reasonable cause within the meaning of section 273B of the Act. It ITA Nos.171 & 172/Hyd/2024 5 was also the submission of the assessee that in none ... remedy/rectify the situation/default. The Ld. DR also emphasised that the practice of cash dealings have been carried out by the assessee without any reasonable cause. 19. We considered carefully submissions of the parties. It is not in dispute that the assessee is a co-operative society which considers itself, though

Syndicate Retired Employees and Other Mutually Aided Coop Credit Society Ltd, Kurnool vs. Income Tax Officer, Ward-1, Kurnool

ITA 171/HYD/2024[2017-18]Status: DisposedITAT Hyderabad23 Oct 2024AY 2017-18

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Madan Mohan Meena, SR-DR
Section 143(3)Section 269SSection 269TSection 271D

prohibition to do so. The assessee pleaded before the Ld. JCIT and the Ld. CIT(A) that for its default there existed reasonable cause within the meaning of section 273B of the Act. It ITA Nos.171 & 172/Hyd/2024 5 was also the submission of the assessee that in none ... remedy/rectify the situation/default. The Ld. DR also emphasised that the practice of cash dealings have been carried out by the assessee without any reasonable cause. 19. We considered carefully submissions of the parties. It is not in dispute that the assessee is a co-operative society which considers itself, though

Vegesna Hare Ramaraju, Viskahapatnam vs. Income Tax Officer, Ward-3(1), Visakhapatnam

In the result, appeal of the assessee is allowed

ITA 351/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam23 Oct 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble(In आयकर अपील सं./ I.T.A. No.351/Viz/2024) (िनधा"रण वष" / Assessment Year: 2017-18)) Vegesna Hare Ramaraju, Vs. Income Tax Officer, Visakhapatnam. Ward-3(1), Pan: Accpv9401E Visakhapatnam. (अपीलाथ"/ Appellant) (""थ"/ Respondent) अपीलाथ" की ओर से/ Appellant By : Sri Gvn Hari, Ar ""ाथ" की ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 269SSection 271DSection 273BSection 274

NFAC that the Ld. AO ought to have considered that the case of the assessee falls within the scope of “reasonable cause” as provided U/s. 273B of the Act. Further, the assessee also contended before the Ld. CIT(A)-NFAC that the penalty levied U/s. 271D ... 271D of the Act. b) The Ld. CIT(A) ought to have held that the case of the appellant falls within the scope of reasonable cause contemplated U/s. 273B of the Act. 5. Any other ground that may be urged at the time of appeal hearing.” 4. At the outset

Attinkara Electronics, Chengannur vs. Commissioner of Income-Tax (Appeals), Delhi

Appeal is allowed in above terms

ITA 564/COCH/2024[2015-16]Status: DisposedITAT Cochin23 Oct 2024AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhattinkara Electronics The Income Tax Officer 1 Attinkara Building Ward - 1 & Tps, Thiruvalla Vs. M.C. Road, Chengannur 689121 [Pan: Aaifa1283D] (Appellant) (Respondent)

For Appellant: Shri Anumon Antony, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 139(1)Section 143(3)Section 250Section 271BSection 273

authorities’ respective findings that it had also filed the medical record of its authorised representative which has been wrongly rejected as not forming a “reasonable cause” u/sec.273 of the Act. 4. Faced with this situation, learned Sr. D.R. could hardly dispute that this tribunal has already accepted assessee’s very

Celestial Infrastructure Pvt Ltd, Ambalamugal vs. DCIT, Corporate Circle-1(1), Ernaluam

In the result, appeal is "Dismissed"

ITA 160/COCH/2024[2009-2010]Status: DisposedITAT Cochin23 Oct 2024AY 2009-2010

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhcelestial Infrastructure (P) Ltd. Dcit, Corporate Circle - 1(1) Aiswarya Towers Cr Building, Is Press Road Hoc Junction, Ambalamugal Vs. Kochi 682018 Ernakulam 682302 [Pan: Aaccc6737F] (Appellant) (Respondent)

For Appellant: Shri Thomas Thomas, CAFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 143(1)Section 249Section 249(3)Section 250

date of the limitation for filing of the appeal, but when it allows the limitation to expire and come forward with an explanation enumerating reasonable causes for not filing the appeal within the time prescribed under the statute, then the causes so shown must establish that because of some event

Role Agencies, Kumbalam vs. Income Tax Officer, Ernakulam

Appeal is allowed in above terms

ITA 643/COCH/2023[2016-17]Status: DisposedITAT Cochin23 Oct 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhrole Agencies The Income Tax Officer 15/390A, Kumblam C.R. Building, I.S. Press Panangad S.O. Vs. Road Ernakulam 682506 Kochi 682018 [Pan: Aarfr6919E] (Appellant) (Respondent)

For Appellant: ------ None -------For Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 139(1)Section 143(3)Section 250Section 271BSection 273B

learned lower authorities throwing light on circumstances beyond it’s control. We conclude in these facts that the assessee’s explanation indeed forms a “reasonable cause” within the meaning of sec.273B of the Act. The impugned penalty is deleted therefore. 3. Delay of 164 days in filing the instant appeal

Lots Shipping Limited, Kochi vs. JCIT TDS, Kochi

Appeal are Dismissed

ITA 608/COCH/2023[2011-12]Status: DisposedITAT Cochin23 Oct 2024AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: ------- None -------For Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 250Section 271CSection 273BSection 274

Dharmendra Textile Processors (306 ITR 277). The AO has further observed that the assessee has not been able to make out any case for reasonable cause u/s.273B of the Act. The AO has further relied on the Kerala High Court decision in the case of M/s U.S. Technologies International Pvt.Ltd ... amount late. I find that the assessee has not been able to explain the reasons for belated deposit and no case for reasonable cause has been made out either during the penalty proceedings before the JCIT or during the appellate proceedings. Therefore, I do not see any reason to interfere

Lots Shipping Limited, Kochi vs. JCIT TDS, Kochi

Appeal are Dismissed

ITA 607/COCH/2023[2010-11]Status: DisposedITAT Cochin23 Oct 2024AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: ------- None -------For Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 250Section 271CSection 273BSection 274

Dharmendra Textile Processors (306 ITR 277). The AO has further observed that the assessee has not been able to make out any case for reasonable cause u/s.273B of the Act. The AO has further relied on the Kerala High Court decision in the case of M/s U.S. Technologies International Pvt.Ltd ... amount late. I find that the assessee has not been able to explain the reasons for belated deposit and no case for reasonable cause has been made out either during the penalty proceedings before the JCIT or during the appellate proceedings. Therefore, I do not see any reason to interfere

Kns Hajee Shaik Labbai Sahib Company Pvt Ltd, Kozhikode vs. The ITO Circle1 (1) & Tps, Kozhikode

Appeal is allowed

ITA 442/COCH/2023[2016-17]Status: DisposedITAT Cochin23 Oct 2024AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhkns Hajee Shaik Labbai Sahib The Income Tax Officer Company Pvt. Ltd. Ward - 1(1) & Pps 7/189, Court Road Vs. Kozhikode Kozhikode 673001 [Pan: Aabck4699P] (Appellant) (Respondent)

For Appellant: Shri Shammem Ahmed, AdvocateFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 143(3)Section 250Section 271BSection 273B

various communication gaps, etc. with the auditor’s office. That being the case, we hold that the assessee has been able to prove the “reasonable cause” u/sec.273B and, therefore, we delete the impugned penalty u/sec.271B of the Act in very terms. 3. This assessee’s appeal is allowed. Order pronounced

Libo John, Thodupuzha vs. The ITO Ward 1 & Tps, Thodupuzha

Appeal is allowed in above terms

ITA 440/COCH/2023[2017-18]Status: DisposedITAT Cochin23 Oct 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhlibo John The Income Tax Officer Puthenpurayil House Ward - 1 & Tps Kumaramangalam P.O. Vs. Thodupuzha Thodupuzha, Idukki 685584 [Pan: Aijpj7754P] (Appellant) (Respondent)

For Appellant: ------- None ------For Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 143(3)Section 250Section 271BSection 273B

various communication gaps, etc. with the auditor’s office. That being the case we hold that the assessee has been able to prove a “reasonable cause” u/sec.273B of the Act and, therefore, we delete the impugned penalty. Ordered accordingly. 3. This assessee’s appeal is allowed in above terms. Order

Junaid Vaverukunnel Pareed, Idukki vs. The ITO Ward 1 & Tps, Thodupuzha

Appeal is allowed in above terms

ITA 438/COCH/2023[2017-18]Status: DisposedITAT Cochin23 Oct 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhjunaid Vaverukunnel Pareed The Income Tax Officer Vaverukunnel House Ward - 1 & Tps Kaliyar P.O. Vs. Thodupuzha Thodupuzha 685607 [Pan: Cehpp6363N] (Appellant) (Respondent)

For Appellant: ------- None ------For Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 139(1)Section 250Section 271BSection 273BSection 44A

period. 3. Faced with this situation, we find no merit in Revenue’s vehement contentions supporting the impugned sec.271B penalty since there exists a “reasonable cause” u/sec.273B indicating circumstances beyond assessee’s control. This penalty stands deleted accordingly. 4. This assessee’s appeal is allowed in above terms. Order pronounced

Surabhi Surendranathan, Kozhikode vs. The ITO Ward 2, Kannur

Appeal is allowed

ITA 423/COCH/2023[2017-18]Status: DisposedITAT Cochin23 Oct 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhsurabhi Surendranathan The Income Tax Officer-2 Surabhilam, Naluthura Kannothumchal Pandakkal, Mahe Vs. Kannur 670006 Kozhikode 673310 [Pan: Fsvps8520K] (Appellant) (Respondent)

For Appellant: Shri Arun Raj S., AdvocateFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 143(3)Section 250Section 271BSection 273B

duly filed her audit report well before the due date for filing the return. That being the case the assessee’s explanation has reasonable cause within the meaning of Section 273B of the Act; therefore, the impugned penalty is deleted. 3. This assessee’s appeal is allowed. Order pronounced

Rajalakshmi: Kairali Gas Agencies, Kozhikode vs. ACIT, Kozhikode

Appeal is allowed

ITA 331/COCH/2023[2017-18]Status: DisposedITAT Cochin23 Oct 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singhrajalakshmi: Kairali Gas Agencies Assistant Commissioer Ulliyeri, Kozhikode 673327 Of Income Tax Vs. [Pan: Bbzpr7228C] Kozhikode (Appellant) (Respondent)

For Appellant: Shri Reshal, AdvocateFor Respondent: Smt. V. Swarnalatha, Sr. D.R
Section 139(1)Section 143(3)Section 250Section 271BSection 273B

submission of tax audit report and assessment in these facts and circumstances. We thus conclude in this peculiar fact that there indeed exists a reasonable cause within the meaning of section 273B of the Act beyond the assessee’s control which prevented it from filing the tax audit report within

Muthusamy Ayyakannu, Chennai vs. ITO, Non Crop Ward 7(1), Chennai

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

ITA 2162/CHNY/2024[2016-17]Status: DisposedITAT Chennai23 Oct 2024AY 2016-17

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 2162/Chny/2024 िनधा"रण वष" / Assessment Year: 2016-17 Muthusamy Ayyakannu, Income Tax Officer, No.13/23, Padikuppam Road V. Non Corp Ward -7(1), Periyarnagar, Chennai. Anna Nagar, West Anna Nagar S.O, Chennai – 600 040. [Pan: Cfdpa-0864-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Mr. N.V. Krishnan, Advocate अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 22.10.2024 घोषणा की तारीख/Date Of Pronouncement : 23.10.2024 आदेश /O R D E R

For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 131Section 143(3)Section 147Section 148Section 69

appeal filed by the assessee, for which petition for condonation of delay has been filed. In the interests of justice and considering the reasonable cause, we condone delay in filing of appeal and admit appeal filed by the assessee for adjudication. 3. The assessee is an individual, filed his return