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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

Shri Yasir Bilal Khan, Srinagar vs. Deputy Commissioner of Income Tax Central Circle, Jammu

In the result, the appeals of the assessee in ITA Nos

ITA 153/ASR/2022[2014-15]Status: DisposedITAT Amritsar17 Feb 2023AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Mrs. Kanchan Garg, Sr. DR
Section 250(6)Section 271ASection 271BSection 44A

consider the defect of challan payment head& accept the appeal. Further the appeal is filed with delay for 31 days. Related to the delay in filing appeal the assessee filed a petition for condonation of delay, the assessee’s relative was seriously ill and assessee was forget to submit

Shri Yasir Bilal Khan, Srinagar vs. Deputy Commissioner of Income Tax Central Circle, Jammu

In the result, the appeals of the assessee in ITA Nos

ITA 152/ASR/2022[2012-13]Status: DisposedITAT Amritsar17 Feb 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Mrs. Kanchan Garg, Sr. DR
Section 250(6)Section 271ASection 271BSection 44A

consider the defect of challan payment head& accept the appeal. Further the appeal is filed with delay for 31 days. Related to the delay in filing appeal the assessee filed a petition for condonation of delay, the assessee’s relative was seriously ill and assessee was forget to submit

Shri Yasir Bilal Khan, Srinagar vs. Deputy Commissioner of Income Tax Central Circle, Jammu

In the result, the appeals of the assessee in ITA Nos

ITA 151/ASR/2022[2011-12]Status: DisposedITAT Amritsar17 Feb 2023AY 2011-12

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: NoneFor Respondent: Mrs. Kanchan Garg, Sr. DR
Section 250(6)Section 271ASection 271BSection 44A

consider the defect of challan payment head& accept the appeal. Further the appeal is filed with delay for 31 days. Related to the delay in filing appeal the assessee filed a petition for condonation of delay, the assessee’s relative was seriously ill and assessee was forget to submit

Shri Parmeshbhai Parbatbhai Chandera, Gir-Somnath vs. The ITO, WD-4, Veraval

In the result, the appeal

ITA 157/RJT/2021[2017-18]Status: DisposedITAT Rajkot15 Feb 2023AY 2017-18

Bench: The Hearing Of Appeal.”

For Appellant: Shri Shreyash Khalpada, Ld. A.RFor Respondent: Shri B.D. Gupta, Sr. D.R
Section 139(1)Section 143Section 143(1)Section 43B

more grounds of appeal or before the hearing of appeal.” At the outset we observe that there is a 33 days delay in filing appeal. However, since the appeal was filed during Covid period, the delay is hereby being condoned. 3. The brief facts in relation to this case

The Julana Primary Cooperative Agriculture and Rural Development Bank, Haryana vs. JCIT, TDS Range, Karnal

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

ITA 579/DEL/2021[2010-11]Status: DisposedITAT Delhi09 Feb 2023AY 2010-11

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kediaआ.अ.सं/.I.T.A Nos.577 To 579/Del/2021 िनधा"रणवष"/Assessment Years: 2008-09 To 2010-11 बनाम The Julana Primary Cooperative Jcit, Vs. Agriculture & Rural Tds Range, Karnal. Development Bank, Near Lajwana Chungi Karsol Road, Julanamandi. Pan No. Rtkt01958F अपीलाथ" Appellant ""यथ"/Respondent

Section 272A(2)(k)

appeal (07.12.2019) in form 35. 3. That the learned appellate authority wrongly and illegally attributed the delay in service of order as delay in filing appeal, (date of order 09.03.2012 & date of service 19.11.2019). 4. That the learned appellate authority wrongly and illegally passed ex-parte order ignoring the principle ... Supreme Court in suomoto writ petition (civil no. 3/2020) dated 08.03.2021 extended the limitation period for filing appeals the delay in filing appeals by the assessee before the Tribunal is condoned. 3. These appeals of the assessee were dismissed ex parte order by the Ld. CIT(Appeals) on limitation

The Julana Primary Cooperative Agriculture and Rural Development Bank, Haryana vs. JCIT, TDS Range, Karnal

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

ITA 578/DEL/2021[2009-10]Status: DisposedITAT Delhi09 Feb 2023AY 2009-10

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kediaआ.अ.सं/.I.T.A Nos.577 To 579/Del/2021 िनधा"रणवष"/Assessment Years: 2008-09 To 2010-11 बनाम The Julana Primary Cooperative Jcit, Vs. Agriculture & Rural Tds Range, Karnal. Development Bank, Near Lajwana Chungi Karsol Road, Julanamandi. Pan No. Rtkt01958F अपीलाथ" Appellant ""यथ"/Respondent

Section 272A(2)(k)

appeal (07.12.2019) in form 35. 3. That the learned appellate authority wrongly and illegally attributed the delay in service of order as delay in filing appeal, (date of order 09.03.2012 & date of service 19.11.2019). 4. That the learned appellate authority wrongly and illegally passed ex-parte order ignoring the principle ... Supreme Court in suomoto writ petition (civil no. 3/2020) dated 08.03.2021 extended the limitation period for filing appeals the delay in filing appeals by the assessee before the Tribunal is condoned. 3. These appeals of the assessee were dismissed ex parte order by the Ld. CIT(Appeals) on limitation

The Julana Primary Cooperative Agriculture and Rural Development Bank, Haryana vs. JCIT, TDS Range, Karnal

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

ITA 577/DEL/2021[2008-09]Status: DisposedITAT Delhi09 Feb 2023AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kediaआ.अ.सं/.I.T.A Nos.577 To 579/Del/2021 िनधा"रणवष"/Assessment Years: 2008-09 To 2010-11 बनाम The Julana Primary Cooperative Jcit, Vs. Agriculture & Rural Tds Range, Karnal. Development Bank, Near Lajwana Chungi Karsol Road, Julanamandi. Pan No. Rtkt01958F अपीलाथ" Appellant ""यथ"/Respondent

Section 272A(2)(k)

appeal (07.12.2019) in form 35. 3. That the learned appellate authority wrongly and illegally attributed the delay in service of order as delay in filing appeal, (date of order 09.03.2012 & date of service 19.11.2019). 4. That the learned appellate authority wrongly and illegally passed ex-parte order ignoring the principle ... Supreme Court in suomoto writ petition (civil no. 3/2020) dated 08.03.2021 extended the limitation period for filing appeals the delay in filing appeals by the assessee before the Tribunal is condoned. 3. These appeals of the assessee were dismissed ex parte order by the Ld. CIT(Appeals) on limitation

The Kekri Cooperative Marketing Society, Ajmer vs. ITO, Ward-2(3), Ajmer

In the result, the appeal of the assessee is allowed

ITA 277/JPR/2022[2013-14]Status: DisposedITAT Jaipur08 Feb 2023AY 2013-14

Bench: Hon’ble SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Sunil Porwal, CAFor Respondent: Mrs. Monisha Choudhary, JCIT
Section 249(3)Section 271(1)Section 80P

submitted detailed reasons in writing and it is once again requested to condone the delay and consider the facts in merit. The delay in filing appeal was beyond the control of the assessee. 2.3 On the other hand, the ld. DR supported the order

Punjab State Warehousing Corporation, Hoshiarpur vs. Income Tax Officer - TDS-1, Jalandhar

In the result, the appeals filed are allowed for statistical purpose

ITA 646/ASR/2019[2014-15]Status: DisposedITAT Amritsar31 Jan 2023AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 156Section 194CSection 249Section 264Section 5

explain the delay in filing of the appeal. Therefore, the request for condonation in filing of appeal is dismissed.” 5. To explain the delay in filing appeal from 01.04.2014 to 17.07.2014, the assessee has filed condonation petition and written submission as under:- That the Hon’ble ITAT in the order

Punjab State Warehousing Corporation, Hoshiarpur vs. Income Tax Officer TDS-1, Jalandhar

In the result, the appeals filed are allowed for statistical purpose

ITA 645/ASR/2019[20103-14]Status: DisposedITAT Amritsar31 Jan 2023

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 156Section 194CSection 249Section 264Section 5

explain the delay in filing of the appeal. Therefore, the request for condonation in filing of appeal is dismissed.” 5. To explain the delay in filing appeal from 01.04.2014 to 17.07.2014, the assessee has filed condonation petition and written submission as under:- That the Hon’ble ITAT in the order

Punjab State Warehousing Corporation, Hoshiarpur vs. Income Tax Officer TDS-1`, Jalandhar

In the result, the appeals filed are allowed for statistical purpose

ITA 644/ASR/2019[2012-13]Status: DisposedITAT Amritsar31 Jan 2023AY 2012-13

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 156Section 194CSection 249Section 264Section 5

explain the delay in filing of the appeal. Therefore, the request for condonation in filing of appeal is dismissed.” 5. To explain the delay in filing appeal from 01.04.2014 to 17.07.2014, the assessee has filed condonation petition and written submission as under:- That the Hon’ble ITAT in the order

Prashant R. Mamlatdarna, Bharuch vs. ITO-Ward-1(5), Bharuch

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

ITA 242/SRT/2022[2010-11]Status: DisposedITAT Surat30 Jan 2023AY 2010-11

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकर अपील सं./Ita No.242/Srt/2022 (िनधा"रणवष" / Assessment Year: (2010-11) (Physical Court Hearing) Prashant R Mamlatdarna Income Tax Officer, Ward-1(5), 6, Pritam Society No.1 Kasak, 1St Floor, Harkunj Building, Vs. Bharuch-392001 Above Bank Of Baroda, Station Road, Bharuch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adepm 4216 H (Appellant ) (Respondent)

For Appellant: Ms. Himali Mistry, C.AFor Respondent: Shri Vinod Kumar–Sr-DR
Section 144Section 250

pandemic, to supply necessary documents and papers to his consultant. Considering the submission of both the parties, we find that the assessee’s delay in filing appeal falls within the period covered by the order of Hon'ble Apex Court in Suo Motu Writ Petition (C) No.3 of 2022 dated

Shri Dalubhai R.Chauhan, Surat vs. Income Tax Officer(International Taxation), Surat

ITA 141/SRT/2019[2014-15]Status: DisposedITAT Surat24 Jan 2023AY 2014-15

Bench: Shripawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.141/Srt/2019 ("नधा"रणवष" / Assessment Year: (2014-15) (Physical Court Hearing) Shri Dalubhai Raghabhai Chauhan Income Tax Officer, International 201, Swastik Heights, B/H Terapanth Taxation, Anavil Business Centre, Vs. Bhavan, City Light Road, Surat- Adajan, Surat-395002 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Atzpc 0952 H (Assessee) (Respondent)

For Appellant: Shri Rakesh Shah, C.AFor Respondent: Shri Vinod Kumar– Sr.DR
Section 143(3)Section 56(2)(vii)

disregarding the provisions of the statute. As I am the citizen of UK and not well versed with Indian income tax law, the delay in filing appeal may kindly be condoned, I shall always remain grateful for the act of kindness. Whatever stated above is true to the best ... Chauhan 4. Based on contents of the petition, Ld. counsel pleads that assessee has explained the bona fide and sufficient reasons for delay in filing appeal before the Tribunal. The ld Counsel explained that assessee is a citizen of United Kingdom and on relevant time he was not in India

Nirav Bipinbhai Vaghasiya, Surat vs. Income Tax Officer, Ward 3(2)(1), Surat

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

ITA 90/SRT/2022[2018-19]Status: DisposedITAT Surat16 Jan 2023AY 2018-19

Bench: Shri Pawan Singhआ.अ.सं./Ita No.90/Srt/2022 (Ay 2018-19) (Hearing In Physical Court) Nirav Bipinbhai Vaghasiya Income Tax Officer, 59, Shradha Deep Society, Ward-3(2)(1), Surat Vs Singanpore, Causewayroad, Ved Road, Surat-395004 Pan No: Amupv 4454 H अपीलाथ"/Appellant ""यथ" /Respondent "नधा"रती क" ओर से /Assessee By None राज"व क" ओर से /Revenue By Shri Vinod Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing 04.01.2023 उ"घोषणा क" तार"ख/Date Of 16.01.2023 Pronouncement Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By Assessee Is Directed Against The Order Of National Faceless Appeal Centre, Delhi [For Short To As “Nfac”/Ld.Cit(A) Dated 28.12.2021 For Assessment Year 2018-19, Which In Turn Arises Out Assessment Order Passed By Asst. Director Of Income Tax, Centralized Processing Centre (Cpc) Bengaluru Under Section 143(1) Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 23.10.2019. The Assessee Has Raised The Following Grounds Of Appeal:- “1. In Law & In Facts & Circumstances Of The Case, The Learned Cit(A) National Faceless Appeal Centre Erred In Not Allowing Tds Nirav B Vaghasiya Credit Of Rs.2,21,000 Though The Same Is Duly Reflected In Form No 26As Of The Appellant. 1.1 In Law & In Facts & Circumstances Of The Case, The Learned Cit(A) National Faceless Appeal Centre Erred In Not Allowing The Tds Credit Of Rs.2,21,000 Though The Capital Gain On Sale Of Property Was Offered For Taxation In The Hands Of Partnership Form & No Revenue Loss Incurred To The Department. 1.2 In Law & In Facts & Circumstances Of The Case, The Learned Cit(A) National Faceless Appeal Centre Erred In Not Allowing Tds Credit To The Appellant Though No Income Against Such Tds Credit Was Earned By The Appellant Against Such Tds Credit.

Section 143(1)Section 154Section 194ISection 254(1)

passed by NFAC, Delhi/Ld. CIT(A) on 28.12.2021, however, assessee filed appeal before Tribunal on 19.04.2022. Thus, there is delay of fifty-two delay in filing appeal. The assessee has placed on record copy of order of Hon'ble Apex Court dated 10.01.2022 passed by in Miscellaneous Application

Shri Jk Ramesh Gandhi, Panruti vs. DCIT, Cuddalore Cirlce, Cuddalore

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

ITA 547/CHNY/2021[2016-2017]Status: DisposedITAT Chennai21 Dec 2022AY 2016-2017

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.547/Chny/2021 िनधा"रण वष" /Assessment Year: 2016-17 Shri J.K.Ramesh Gandhi, V. The Dy. Commissioner- 190, Annai Indira Gandhi Salai, Of Income Tax, Panruti-607 108. Cuddalore Circle, Income Tax Office, Soorappa Naicken Chavadi, Cuddalore-607 002. [Pan: Ammpr 0026 K] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.Philip George, Adv. ""यथ" क" ओर से /Respondent By : Mr. Ar.V.Sreenivasan, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 13.12.2022 घोषणा क" तारीख /Date Of Pronouncement : 21.12.2022

For Respondent: Mr. AR.V.Sreenivasan
Section 133ASection 147Section 148

before Courts and Tribunals and thus, considering facts and circumstances of the case and also in the interest of natural justice, we condone delay in filing appeal filed by the assessee. 3. The brief facts of the case are that the assessee is a Proprietor of M/s.JKR Tex. The assessee

A.R.A.P Enterprises P Ltd, Chennai vs. ACIT(OSD), Ncr-1, Chennai

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

ITA 535/CHNY/2021[2015-16]Status: DisposedITAT Chennai14 Dec 2022AY 2015-16

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.535/Chny/2021 िनधा"रण वष" /Assessment Year: 2015-16 M/S.A.R.A.P. Enterprises Pvt. Ltd., V. The Asst. Commissioner Of New No.35-37, Old No.17-18, Income Tax (Osd), Gandhi Irwin Road, Ncr-1, Chennai. Egmore, Chennai-600 008. [Pan: Aagca 9262 R] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.R.Venkatraman, Irs & Mr.R.Viswanathan, Ca ""यथ" क" ओर से /Respondent By : Mr. Ar.V.Sreenivasan, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 07.12.2022 घोषणा क" तारीख /Date Of Pronouncement : 14.12.2022

For Respondent: Mr. AR.V.Sreenivasan
Section 37(1)

before Courts and Tribunals and thus, considering facts and circumstances of the case and also in the interest of natural justice, we condone delay in filing appeal filed by the assessee. 3. The assessee has raised the following grounds of appeal: 1. The order of the learned

Mrs. Akila Ramesh, Chennai vs. ITO, Ncw - 16(1), Chennai

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

ITA 2378/CHNY/2019[2015-16]Status: DisposedITAT Chennai30 Nov 2022AY 2015-16

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 2378/Chny/2019 िनधा"रण वष" / Assessment Year: 2015-16 Mrs. Akila Ramesh Income Tax Officer, No.1, Balaji Street, V. Non Corporate Ward -16(1), Kodambakkam, Chennai- 34. Chennai – 600 024. [Pan: Ahgpa-4112-N] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. S. Jayakumar, Advocate : Shri. P. Sajit Kumar, Jcit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 24.11.2022 घोषणा क" तारीख/Date Of Pronouncement : 30.11.2022

For Appellant: Shri. S. Jayakumar, Advocate
Section 2(14)

explaining reasons for delay has been filed. The Ld. Counsel for the assessee, referring to petition filed by the assessee submitted that the delay in filing appeal before the Tribunal is neither intentional nor to derive any undue benefit, but beyond the control of the assessee. The Ld. Counsel ... considered relevant contents of petition filed by the assessee for condonation of delay. We find that the assessee has given reasons for delay in filing appeal, as per which the delay has occurred due to collecting necessary evidences, including certificate from revenue authorities to defend her case before the appellant

Venkatesh Securities Ltd., Mumbai vs. The Income Tax Officer-3(3)(4), Mumbai

Appeal is dismissed

ITA 7181/MUM/2018[2009-10]Status: DisposedITAT Mumbai30 Nov 2022AY 2009-10
For Appellant: Shri A K Tribrewal/Saurabh GuptaFor Respondent: Shri Vivek Perumpura
Section 143(3)Section 147

jeopardize the interest of the revenue by delaying the filing of the appeal.” 10. The Learned Authorized Representative for the Appellant submitted that delay in filing appeal deserves to be condoned in view of the decision in the case of Collector, Land Acquisition, Anantnag and Ors. vs. Katiji ... opinion that the respondent beneficiary was not diligent in availing the remedy of appeal. The averments made in the application seeking condonation of delay in filing appeals do not show any acceptable cause to exercise discretion by the Tribunal in favour of the Appellant. In the present case, the additions

Indoco Remidies Limited, Mumbai vs. NFAC, Delhi

Appeal is allowed

ITA 1698/MUM/2022[2018-2019]Status: DisposedITAT Mumbai29 Nov 2022AY 2018-2019
For Appellant: Mr. Madhur AgarwalFor Respondent: Mr. Sandeep Raj
Section 143(3)

matter was taken up for hearing the Learned Authorised Representative for Appellant pointed out the above facts and requested for condonation of delay in filing appeal. He further submitted that since none of the grounds raised in appeal have been adjudicated, all the issues be restored to the file

Yennarkay R.Chiranjeevirathinam, Sivakasi vs. ACIT, CC 2, Madurai

In the result, the appeals filed by the assessee in ITA Nos

ITA 337/CHNY/2021[2014-15]Status: DisposedITAT Chennai23 Nov 2022AY 2014-15
For Appellant: Shri K. Balasubramanian, AdvocateFor Respondent: Shri R. Mohan Reddy, CIT
Section 132Section 143(3)Section 153A(1)(a)Section 153CSection 153C(1)

other cause is attributed by the assessee for this long delay. In view of the fact that there is no reasonable cause and delay in filing appeal minus Covid period is 316 days and total delay is 862 days. Since, there is no reasonable cause adduced, we refuse to condone