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“delay in filing appeal”

AppealsSection 249Section 2491,894 judgments

The decision most relied on for delay in filing appeal is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 judgments on BharatTax.

Leading authorities on delay in filing appeal

Collector, Land Acquisition v. Mst. Katiji
167 ITR 471 · 1987 · Supreme Court
3,926
citing judgments

Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.

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.

Vishin Meghani v. DCIT & Anr
398 ITR 250 · 2017 · High Court
291
citing judgments

This case is cited as an authority supporting the condonation of delay in filing income tax appeals, particularly when an assessee presents a request for such condonation.

Concord of India Insurance Co. Ltd. v. Smt. Nirmala Devi and Others
118 ITR 507 · 1979 · Supreme Court
268
citing judgments

For condoning delay, the term 'sufficient cause' must be interpreted liberally and purposively to advance justice. Delay not tainted by mala fides, gross negligence, or recklessness, and based on honestly obtained legal advice, constitutes sufficient cause.

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.

Land Acquisition, Anantnag and Anr. v. Ms Katiji and Others
167 ITR 5 · 1987 · Supreme Court
164
citing judgments

The principle of 'sufficient cause' for condonation of delay in filing appeals requires a liberal interpretation to ensure substantial justice, but delay will not be condoned if sufficient cause is not satisfactorily explained by the appellant.

Judgments citing delay in filing appeal

Rajendra Kumar Tripathi, Delhi vs. ITO Ward 56(3) Delhi, Delhi

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

ITA 1674/DEL/2024[2019-20]Status: DisposedITAT Delhi14 Aug 2024AY 2019-20

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2019-20 Rajendra Kumar Tripathi Vs. Ito 341, Heritage Tower, Sawan Ward- 56 (3) Cghs Ltd. Plot No.1, Delhi Sector-3, Dwarka, Delhi-110078 Pan No.Abppt7714C (Appellant) (Respondent) Appellant By Sh. Dishant Sethi, Advocate Sh. Shyam Sunder, Advocate Respondent By Ms. Raja Rajeshwari, Sr. Dr. Date Of Hearing: 08/08/2024 Date Of Pronouncement: 14/08/2024 Order Per Sudhir Kumar, Jm: This Appeal By The Assessee Is Directed Against The Order Of The Cit(Appeals)/National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Nfac”] Vide Order Dated 12.02.2024 Pertaining To A.Y. 2019-20 & Arises Out Of The Assessment Order Dated 23.12.2019 Under Section 144/148 Of The Income Tax Act 1961 [Hereinafter Referred As ‘The Act’].

Section 143Section 144Section 249(3)Section 5

filing of appeal for which no sufficient reason has been given by the appellant. The appellant has failed to justify the inordinate delay in filing appeal. From the factual position which emerges it appears that a conscious and considered decision was taken by the assessee at the relevant point ... rival submission of the parties and issue- 6. in-dispute and perused the relevant material on record on the issue of condonation of delay in filing appeal before the Ld. CIT(A). 7. We find that the delay has been caused mainly due to illness and the death

M/S. Arjuna Souhardha Pathina Sahakari Niyamitha, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru

ITA 1221/BANG/2024[2018-19]Status: DisposedITAT Bangalore13 Aug 2024AY 2018-19

Bench: The Ld.Cit(A) Which Was Not Condoned. The Reason That Caused The Delay Is Reproduced In The Impugned Order At Page 3. It Is Submitted By The Ld.Ar That The Assessee Was Advised By The Erstwhile Authorised Representative To Pay The Demand & That There Was No Redressal Mechanism Available Against Such Assessment Order. It Is Stated Therein That The Assessee Thereafter Approached Another Tax Consultant Who Advised The Assessee To File Appeal, That Causing The Delay. The Ld.Ar Submitted That, The Assessee Diligently Filed The Appeal Immediately Upon Receipt Of The Advise From Another Consultant & There Is No Malafide Intention On Behalf Of The Assessee, Though Belatedly. He Thus Prayed For The Remission Of The Issues To Be Considered On Merits. 2.1. The Ld.Dr Though Objected Could Not Controvert That The Delay In Filing The Appeals Before The Ld.Cit(A) Could Not Be Attributable To The Assessee. We Have Perused The Submissions Advanced By Both Sides In The Light Of Records Placed Before Us. 3. From The Submissions Of Assessee Reproduced In The Impugned Order, There Does Not Arise Any Malafide Intention On Behalf Of Assessee For Not Filing The Present Appeals Before The Ld.Cit(A) In The Period Of Limitation. Page 3 Of 6

Section 51

Page 2 of 6 ITA Nos. 1220 & 1221/Bang/2024 2. At the outset, the Ld.AR submitted that there was delay of

Hindustan Marble & Granite, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-1(4), Bengaluru

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

ITA 1091/BANG/2024[2020-21]Status: DisposedITAT Bangalore13 Aug 2024AY 2020-21

Bench: Shri Chandra Poojari & Shri Keshav Dubeyhindustan Marble & Granite Dcit, Central Circle-1(4) Regd. Office: No.5, Lalbagh- Cr Building, Queens Rod Hosur Road, Wilson Garden Vs. Bengaluru 560001 Bangalore 560027 Pan – Aaafh8437Q (Appellant) (Respondent) Assessee By: Shri Narendra Sharma, Advocate Revenue By: Shri V. Parithivel, Jcit-Dr Date Of Hearing: 08.08.2024 Date Of Pronouncement: 13.08.2024 O R D E R Per: Keshav Dubey, J.M.

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri V. Parithivel, JCIT-DR
Section 143(3)Section 250Section 282

Assessee vehemently submitted that the CIT(A) dismissed the appeal on the sole ground that the sufficient cause for delay in filing appeal is not established. The ld A.R. drew our attention to the application for condonation of delay and affidavit filed before the CIT(A), which are part

The Tungabhadra Credit Cooperative Society, Davangere vs. Income Tax Officer, Ward - 1, Davangere

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

ITA 1201/BANG/2024[2017-18]Status: DisposedITAT Bangalore12 Aug 2024AY 2017-18

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

For Appellant: Shri Kotresh K, CAFor Respondent: Ms. Neha Sahay, JCIT-DR
Section 51

1201/Bang/2024 Page 5 of 10 ITA Nos. 1199 to 1201/Bang/2024 2.1. It is submitted by the assessee that the reason causing delay in filing appeals before this Tribunal was because the authorized representative was not following up with the proceedings in respect of all the notices and the impugned order

The Tungabhadra Credit Cooperative Society, Davangere vs. Income Tax Officer, Ward - 1, Davangere

ITA 1200/BANG/2024[2014-15]Status: DisposedITAT Bangalore12 Aug 2024AY 2014-15

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

Section 250

case of AY 2013-14 and delay of 78 days in the case of AY 2014-15 & AY 2017-18. 4. That, the delay in filing appeal is due to the following facts: i. As the income tax compliances were entrusted to Shri D R Shankar, the appellant society depended ... ITAT. 10. The above process of appointing Chartered Accountant at Davangere and Bengaluru took about THREE months' time. 11. Accordingly, the delay in filing appeal is on account of bona fide circumstances beyond the controlof the Appellant Society and not on account of negligence on the part of the Appellant

The Tungabhadra Credit Cooperative Society, Davangere vs. Income Tax Officer, Ward-1, Davangere

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

ITA 1199/BANG/2024[2013-14]Status: DisposedITAT Bangalore12 Aug 2024AY 2013-14

Bench: Smt. Beena Pillai & Shri Waseem Ahmed

For Appellant: Shri Kotresh K, CAFor Respondent: Ms. Neha Sahay, JCIT-DR
Section 51

1201/Bang/2024 Page 5 of 10 ITA Nos. 1199 to 1201/Bang/2024 2.1. It is submitted by the assessee that the reason causing delay in filing appeals before this Tribunal was because the authorized representative was not following up with the proceedings in respect of all the notices and the impugned order

Prakash Madhav Kolhe, Nashik vs. ITO Ward 2(1), Nashik

In the result, both appeal of the assessee are allowed for statistical purpose

ITA 687/PUN/2024[2018-19]Status: DisposedITAT Pune09 Aug 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.686 & 687/Pun/2024 िनधा"रण वष" / Assessment Years : 2017-18 & 2018-19 Prakash Madhav Kolhe, Vs The Income Tax Officer, 3, Shri Shilpa At Radha Sona, Ward-2(1), Nashik. Iti Ambad Link Road, Kamatwada, Nashik-422010. Pan: Aclpk4828P Appellant/ Assessee Respondent / Revenue Assessee By Smt. Abhilasha Pawar – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 08/08/2024 Date Of Pronouncement 09/08/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Passed Under Section 250 Of The Income Tax Act For A.Y.2017-18 & A.Y.2018-19 Both Dated 27.02.2024 Emanating From Penalty Orders Under Section 270A Of The Act. The Grounds Of Appeal Raised By The Assessee For A.Y.2017-18 Are As Under :

Section 249(2)Section 250Section 270A

ground that there has been delay of 403 days in filing appeal. According to ld.CIT(A), there was no sufficient reason for delay in filing appeal. Therefore, ld.CIT(A) dismissed both the appeals of the assessee without discussing the merits of the case. 2.1 The ld.AR submitted that assessee ... stand to benefit by resorting to delay. In fact, he runs a serious risk. We are convinced that there was sufficient reason for delay in filing appeal. Therefore, in the larger interest of justice, we direct the ld.CIT(A) to condone the delay in both these appeals and decide

Prakash Madhav Kolhe, Nashik vs. ITO Ward 2(1) Nashik, Nashik

In the result, both appeal of the assessee are allowed for statistical purpose

ITA 686/PUN/2024[2017-18]Status: DisposedITAT Pune09 Aug 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.686 & 687/Pun/2024 िनधा"रण वष" / Assessment Years : 2017-18 & 2018-19 Prakash Madhav Kolhe, Vs The Income Tax Officer, 3, Shri Shilpa At Radha Sona, Ward-2(1), Nashik. Iti Ambad Link Road, Kamatwada, Nashik-422010. Pan: Aclpk4828P Appellant/ Assessee Respondent / Revenue Assessee By Smt. Abhilasha Pawar – Ar Revenue By Shri Sourabh Nayak – Addl.Cit(Dr) Date Of Hearing 08/08/2024 Date Of Pronouncement 09/08/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Passed Under Section 250 Of The Income Tax Act For A.Y.2017-18 & A.Y.2018-19 Both Dated 27.02.2024 Emanating From Penalty Orders Under Section 270A Of The Act. The Grounds Of Appeal Raised By The Assessee For A.Y.2017-18 Are As Under :

Section 249(2)Section 250Section 270A

ground that there has been delay of 403 days in filing appeal. According to ld.CIT(A), there was no sufficient reason for delay in filing appeal. Therefore, ld.CIT(A) dismissed both the appeals of the assessee without discussing the merits of the case. 2.1 The ld.AR submitted that assessee ... stand to benefit by resorting to delay. In fact, he runs a serious risk. We are convinced that there was sufficient reason for delay in filing appeal. Therefore, in the larger interest of justice, we direct the ld.CIT(A) to condone the delay in both these appeals and decide

Asst. Commissioner of Income Tax, Circle 2(1), Guntur vs. Tulasi Seeds Private Limited, Guntur

In the result, appeal of the revenue is allowed

ITA 169/VIZ/2023[2014-15]Status: DisposedITAT Visakhapatnam08 Aug 2024AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.169/Viz/2023 (निर्धारण वर्ा/ Assessment Year: 2014-15) Asst. Commissioner Of Income Tax V. M/S. Tulasi Seeds Private Limited 3Rd Floor, Standard House, Beside Sbi Door No. 6-4-6, Tulasi House Nagarampalem, Guntur – 522004 4/5 Arundelpet, Guntur Andhra Pradesh Andhra Pradesh [Pan : Aaact8054C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 142(1)Section 143(1)Section 143(3)Section 35Section 36(1)(va)Section 43B

Thereafter the appeal papers prepared and without any further delay, the appeal filed on 02-06- 2023. 4. It is submitted that the delay in filing appeal is neither wanton nor willful, but only because of the above reasons. 5. In view of the above, it is humbly prayed that

Anand Engineering Products Pvt. Ltd., Trichy vs. DDIT, CPC, Bengaluru

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

ITA 1375/CHNY/2024[2015-16]Status: DisposedITAT Chennai07 Aug 2024AY 2015-16

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकरअपील सं./ Ita No.1375/Chny/2024 (िनधा"रणवष" / Assessment Year: 2015-2016) Anand Engineering Products Pvt Vs. The Assessing Officer, Limited, Corporate Ward 1(1) D-56, Developed Plots Estate, Chennai. Thuvakudi, Trichy 620 015. [Pan: Aafca 1512R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri A.S. Ramakrishnan, C.A., ""यथ" क" ओर से /Respondent By : Ms. Gouthami Manivasagam, Irs, Jcit.

For Appellant: Shri A.S. Ramakrishnan, C.AFor Respondent: Ms. Gouthami Manivasagam, IRS, JCIT
Section 115JSection 139(1)Section 143(1)Section 143(1)(a)Section 249(2)(c)Section 249(3)

No.1375/Chny/2024. 4. We have perused the orders of ld.CIT(A) and ld.AO (CPC). We have also gone through the reasons given for delay in filing appeal before ld.CIT(A) in affidavit by the Managing Director of Company. The affidavit of assessee Company is under: ‘’Affidavit of Mr.K.PREMANATHAN aged 57 years

Narendra Singh Shekhawat, Jaipur vs. ITO WD 1(3), Jaipur

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

ITA 817/JPR/2024[2012-13]Status: DisposedITAT Jaipur07 Aug 2024AY 2012-13
For Appellant: Mrs. Suhani Meharwal, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 144

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, "SMC" JAIPUR श्री संदीप गोसाई, न्यायिक

A Bliss of Creator Society, Jaipur vs. Exemption Ward 1, Jaipur

ITA 608/JPR/2023[2012-13]Status: DisposedITAT Jaipur06 Aug 2024AY 2012-13
For Appellant: Shri R.S. Poonia, CA &For Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 11Section 13Section 143

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR श्री संदीप गोसाई, न्यायिक

Smt. Ravishankar Shylaja, Davangere vs. Income Tax Officer, Ward-1, Davangere

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

ITA 624/BANG/2024[2017-18]Status: DisposedITAT Bangalore06 Aug 2024AY 2017-18

Bench: Shri Chandra Poojari (Accountant Member), Shri Keshav Dubey (Judicial Member)

For Appellant: Ms. Sunaina Bhatia, AdvocateFor Respondent: Shri Ganesh R. Gale, Standing Counsel
Section 143(2)Section 143(3)Section 234Section 250Section 68

Assessee vehemently submitted that the ld. ADDL/JCIT(A)-1, Pune / NFAC dismissed the appeal on the sole ground that the sufficient cause for delay in filing appeal is not established. The ld A.R. drew our attention on Sl. No. 14 of Form 35 where the assessee has clearly mentioned that

Satyaprakash Chouhan, Mhow vs. ITO 5 (3), Indore

Appeal is allowed for statistical purpose

ITA 169/IND/2024[2017-18]Status: DisposedITAT Indore05 Aug 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2017-18 Shri Satyaprakash Ito-5(3), Chouhan, Indore 14, Geeta Bhawan Chouhraha Chakkiwale बनाम/ Mahadeo Complex, Vs. Mhow

Section 142(1)Section 143(2)Section 143(3)Section 144Section 253(5)Section 69A

impugned order after logging in to the Income-tax Portwal on 24.01.2024 and thereafter filed present appeal on 24.02.2024. Thus, the delay in filing appeal has occurred due to non-service of impugned order to the email specified by assessee. Ld. AR very humbly submitted that there is no deliberate

Karakurappa, Chikkaballapur vs. Income Tax Officer Ward - 1, Chikkaballapur

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

ITA 986/BANG/2024[2017-18]Status: DisposedITAT Bangalore05 Aug 2024AY 2017-18

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri Koushik, AdvocateFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 133(6)Section 143(1)Section 143(3)Section 249(2)(e)Section 249(3)Section 250

Page 6 of 6 CIT(Appeals) and considering the facts of the case and in the interest of justice, we condone the delay in filing appeal before the CIT(Appeals) and the case is remitted back to the AO for examination of agricultural income declared by the assessee of Rs.21

Gulab Bai, Kota vs. ITO, Income Tax

In the result, the appeal of the assessee is dismissed with no orders as to

ITA 320/JPR/2024[2012-13]Status: DisposedITAT Jaipur02 Aug 2024AY 2012-13
For Appellant: Shri Harish K. Tripathi, AdvocateFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 249(2)Section 249(3)Section 54B

delay condonation application concern it is settled position of law that where the delay was bona fide and there is sufficient cause for delay in filing appeal the delay must be condoned by the appellate authority specially when it is necessary for rendering the substantial justice to the assessee ... very elementary and well understood that courts should not adopt an injustice-oriented approach in dealing with the applications for condonation of the delay in filing appeals and rather follow a pragmatic line to advance substantial justice. 14. It may also be important to point out that though

M.S. Modi and Sons, Jaipur vs. The Assessing Authority, Delhi

ITA 658/JPR/2023[2018-19]Status: DisposedITAT Jaipur02 Aug 2024AY 2018-19
For Appellant: Shri Tarun Mittal, CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 10ASection 270A

आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR श्री संदीप गोसाई, न्यायिक

The Khedbrahma Taluka Primary Teachers Co.Op. Credit Society Ltd., Himatnagar vs. The Income Tax Officer, Ward-1, Himatnagar

In the result, appeal of the assessee in ITA no

ITA 115/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad01 Aug 2024AY 2018-19

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad , Which

For Appellant: Shri Rushin Patel, ARFor Respondent: Ms. Bhavnasingh Gupta, Sr. D.R
Section 143(3)Section 250Section 253(3)Section 80P(2)(d)

19th February 2023 , but has been filed on 28.02.2023 belatedly by 9 days beyond the time stipulated u/s 253(3). The reason for delay in filing appeal is inadvertent mistake by the concerned accountant, who forgot the file the appeal with Tribunal in time. Thus, the assessee pleaded that

Bhujbal Construction Company, Pune vs. ITO Ward 2(2), Pune

The appeal of the assessee stand DISMISSED on above terms

ITA 756/PUN/2024[2013-14]Status: DisposedITAT Pune01 Aug 2024AY 2013-14

Bench: Hon’Ble Shri G. D. Padmahshali & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No. 0756/Pun/2024 निर्धारण वषा / Assessment Year : 2013-14 M/S Bhujbal Construction Company Gat No. 12/29, Someshwar Wadi, Pashan, Haveli, Baner Rd., Pune. Pan: Aaffb7317L . . . . . . . अपीलार्थी / Appellant बिधम / V/S Income Tax Officer, Ward-2(2)Pune-1. . . . . . . . प्रत्यर्थी / Respondent

For Appellant: None for the AssesseeFor Respondent: Mr Umesh Phade [‘Ld. DR’]
Section 143(3)Section 249(2)Section 250Section 40

still continues to be inordinate, substantial & excessive. In the absence of any application/petition and affidavit accompanying corroborative & independent evidence that such inordinate delay in filing appeal before Ld. CIT(A) was occurred for a sufficient cause, it is much less possible for quasi-judicial authority to turn-a-blind

Devendragouda Channaviragouda Hiregoudra, Haveri vs. Income Tax Officer, Ward 1, Haveri, Davangere

In the result, the appeal filed by the assessee stands partly allowed

ITA 561/BANG/2024[2017-18]Status: DisposedITAT Bangalore01 Aug 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2017-18

For Appellant: Shri Balram R. Rao, AdvocateFor Respondent: Advocate, Standing Counsel for Dept
Section 51

therein. We have perused the submissions advanced by both sides in the light of records placed before us. 4. The reason that caused delay in filing appeal before this Tribunal was because the assessee was not having access to the mail id mentioned in Form 35 to which