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“condonation of delay”

AppealsSection 249Section 24912,312 judgments

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

Leading authorities on condonation of delay

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.

Inder Singh v. State of Madhya Pradesh
2025 INSC 382 · 2025 · Supreme Court
267
citing judgments

Non-deliberate procedural delays caused by circumstances beyond control must be condoned in the interest of substantial justice, even if the delay is significant, such as over 1500 days.

Vedabhai v. Santaram
253 ITR 798 · 2002 · Supreme Court
262
citing judgments

When substantial justice and technical considerations are in conflict, substantial justice should be prioritized. Condoning delay requires a cautious approach without malafide or dilatory tactics, and 'sufficient cause' should be interpreted liberally to advance substantial justice.

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.

Judgments citing condonation of delay

Sri Gowri Sankara Sagara (Uppara) Anna Sathra Sangham, Kurnool vs. ITO., Exemption Ward, Hyderabad

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

ITA 1507/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Nov 2025AY 2018-19

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

condoned in the interest of justice. 4. The Ld. DR for the Revenue, on the other hand, did not strongly oppose the condonation of delay in view of the circumstances explained by the assessee during the course of hearing. 5. We have heard both the parties, perused the petition ... affidavit filed by the assessee seeking condonation of delay of 265 days in filing the appeal before the Tribunal. We find that, the reasons explained by the assessee appear to be genuine and bona fide, and constitute reasonable cause for the delay. We further find that the Hon’ble Supreme

Sujatha Kumar, Banashankari vs. Income Tax Officer, Ward-1, Gudur

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

ITA 1439/HYD/2025[2016-17]Status: DisposedITAT Hyderabad19 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1439/Hyd/2025 Assessment Year – 2016-2017 Mrs. Sujatha Kumar, The Income Tax Officer, Bengaluru – 560 085 Ward-1, Gudur-524101. Vs. Andhra Pradesh Pan Ahmpk3172C (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Siddesh Nagraj Gaddi राज" व "ारा /Revenue By: Sri Abhinav Pitta, Sr. Ar

For Appellant: CA Siddesh Nagraj GaddiFor Respondent: Sri Abhinav Pitta, Sr. AR

outset, there is a delay of 97 days in filing the present appeal before the Tribunal. The assessee has filed an application for condonation of delay as well as an affidavit explaining the cause of delay. The learned Authorised Representative of the Assessee has submitted that the assessee ... assessee be admitted for adjudication on merits. 3. On the other hand, the learned DR for the Revenue has objected to the condonation of delay and submitted that the conduct of the assessee would show that she was negligent about the proceedings before the Assessing Officer as well

Arul Sundaram, Hyderabad vs. ITO., Ward-12(1), Hyderabad

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

ITA 1276/HYD/2025[2016-17]Status: DisposedITAT Hyderabad19 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1276/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Arul Sundaram Vs. Income Tax Officer Hyderabad Ward 12(1) Pan:Awaps1005P Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate H Srinivasulu राज" व "ारा/Revenue By:: Shri R. Kumaran, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 12/11/2025 घोषणा की तारीख/Pronouncement: 19/11/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Arul Sundaram (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 27.01.2025 For The A.Y. 2016-17. 2. At The Outset, It Is Observed That There Is A Delay Of 129 Days In Filing Of The Appeal Before This Tribunal. The Assessee Has Filed A Condonation Petition Along With A Copy Of The Affidavit

For Appellant: Advocate H SrinivasuluFor Respondent: : Shri R. Kumaran, Sr. DR
Section 144BSection 147

appeal. Considering the medical condition of the assessee and the circumstances explained, we find it appropriate to adopt a liberal approach and condone the delay in the interest of substantial justice. Accordingly, the delay of 129 days in filing the appeal is condoned, and the appeal is admitted for adjudication ... order of Ld. CIT (A), the assessee is now in appeal before this Tribunal. The Ld. AR submitted that, as explained while seeking condonation of delay, due to reasons beyond the control of the assessee, he could not respond to the notices issued by the Ld. CIT(A) during

Hitec Cyberspazio LLP, Hyderabad vs. DCIT., Circle-6(1), Hyderabad

ITA 1206/HYD/2025[2022-23]Status: DisposedITAT Hyderabad19 Nov 2025AY 2022-23

Bench: Us:

Section 142(1)Section 143(2)Section 143(3)Section 69

facts and law while passing the order. 2. The Learned CIT(Appeals) is not justified in rejecting the plea of the appellant for condonation of delay in filing of appeal even though the appellant firm has valid and sufficient reasons for occurrence of such delay. The Learned CIT(Appeals) ought ... hearing of the appeal submitted, that the CIT(A) had grossly erred in law and facts of the case by declining to condone the delay of 18 days that was involved in the appeal filed before him. Elaborating on his contention, the Ld. AR submitted that the delay in filing

Assistant Commissioner Income Tax, Central Circle -4(1), Kolkata vs. Victor Tradelink Private Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 2310/KOL/2024[2013]Status: DisposedITAT Kolkata19 Nov 2025

Bench: Shri Rajesh Kumar (Accountant Member), Shri Pradip Kumar Choubey (Judicial Member)

Section 139Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 153ASection 153CSection 250Section 68

days. The revenue has filed a petition for condonation of the delay. After considering the reasons cited in the petition for condonation of delay, we find that the reasons are valid and consequently, the delay in filing the appeal is hereby condoned and we proceed to dispose of the appeal

Arulmigu Vaikunda Perumal and Embarswamy Devasthanam, Kanchipuram vs. ITO, Exemptions Ward-2, Chennai

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

ITA 2525/CHNY/2025[2018-19]Status: DisposedITAT Chennai19 Nov 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2525/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Arulmiguvaikunda The Income Tax Officer, Perumal & Embarswamy Vs. Exemptions Ward 2, Devasthanam, Chennai. No.01, Sunguvachatram, Sungavachatram S.O, Sriperumbudur, Kanchipuram – 602 105. Pan: Aafta 4259C (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S.P. Chidambaram, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 19.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 19.11.2025

For Appellant: Shri S.P. Chidambaram, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 144BSection 147Section 148Section 148ASection 250

There is a delay of 43 days in filing this appeal before the Tribunal. The Assessee Trust has filed a petition for condonation of delay along with the supporting affidavit stating therein the reasons for belated filing of this appeal. On perusal of the reasons stated in the affidavit ... view that no latches can be attributed to the assessee as there is sufficient cause for belated filing of this appeal. Hence, we condone the delay and proceed to dispose off the appeal on merits. 3. At the very outset, we notice that the assessee has filed a legal ground

The Rainbow Bridge (Trust), Coimbatore vs. CIT, Exemptions, Chennai

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

ITA 2510/CHNY/2025[-]Status: DisposedITAT Chennai19 Nov 2025

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 2509 & 2510/Chny/2025

For Appellant: Shri K. Muthukumar, CAFor Respondent: Shri Shiva Srinivas, CIT
Section 12ASection 5Section 80G

There is a delay of 346 days in filing these appeals before the Tribunal. The Assessee Trust has filed a petition for condonation of delay along with the supporting affidavit stating therein the reasons for belated filing of these appeals. 3) That the trust had been advised by the legal ... limitation. Nevertheless, the appeal had been filed before this Hon'ble Income Tax Appellate Tribunal on date 11.09.2025 accompanied by an application for condonation of delay as provided under section 5 of Ine LIMITATION ACT, 1963 4) That in this way there is a delay of 353 days for which

The Rainbow Bridge (Trust), Coimbatore vs. CIT, Exemptions, Chennai

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

ITA 2509/CHNY/2025[-]Status: DisposedITAT Chennai19 Nov 2025

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 2509 & 2510/Chny/2025

For Appellant: Shri K. Muthukumar, CAFor Respondent: Shri Shiva Srinivas, CIT
Section 12ASection 5Section 80G

There is a delay of 346 days in filing these appeals before the Tribunal. The Assessee Trust has filed a petition for condonation of delay along with the supporting affidavit stating therein the reasons for belated filing of these appeals. 3) That the trust had been advised by the legal ... limitation. Nevertheless, the appeal had been filed before this Hon'ble Income Tax Appellate Tribunal on date 11.09.2025 accompanied by an application for condonation of delay as provided under section 5 of Ine LIMITATION ACT, 1963 4) That in this way there is a delay of 353 days for which

Sri Muthu Agencies, Puducherry vs. ITO, Ward-3, Puducherry

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

ITA 2507/CHNY/2025[2018-19]Status: DisposedITAT Chennai19 Nov 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2507/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Sri Muthu Agencies, The Income Tax Officer, No.9, 3Rd Cross, Vs. Ward 3, Sri Ramnagar, Puducherry Achariyapuram, Villianur, Puducherry – 605 110. Pan: Achfs 9277N (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri H. Yeshwanth Kumar, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 19.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 19.11.2025

For Appellant: Shri H. Yeshwanth Kumar, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 144BSection 147Section 148Section 250

There is a delay of 11 days in filing this appeal before the Tribunal. The Assessee has filed a petition for condonation of delay along with the supporting affidavit stating therein the reasons for belated filing of this appeal. On perusal of the reasons stated in the affidavit ... view that no latches can be attributed to the assessee as there is sufficient cause for belated filing of this appeal. Hence, we condone the delay and proceed to dispose off the appeal on merits. 3. At the very outset, we notice that the assessee has filed a legal ground

Kiramony Swami Dhas, Chennai vs. ITO-Ncw 19.4, Chennai

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

ITA 2376/CHNY/2025[2015-16]Status: DisposedITAT Chennai19 Nov 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

For Appellant: NoneFor Respondent: Mr. Krishna Murthy AT, JCIT
Section 147Section 148

case and to meet the ends of justice, we deem it fit to provide one more opportunity to the assessee. Therefore, we condone the delay in filing the before ld.CIT(A) as the assessee had filed the condonation of delay in his form 35 itself and hence, we set aside

Dharmesh Girish Dixit, Mumbai vs. Income Tax Officer, WD-41(3)(1), Mumbai

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

ITA 5622/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Nov 2025AY 2018-19

Bench: Smt. Beena Pillai & Smt.Renu Jauhri

For Appellant: Mr. Jay ThakkarFor Respondent: Shri Annavaran Kosuri- Sr. AR
Section 143(3)Section 250Section 270ASection 271ASection 56Section 68Section 80C

5622/mum/2025. 1.0 On facts and circumstances of the case and in Law, Ld. CIT(A) erred in not condoning the delay in filing the penalty appeal of 722 days and ought to have considered the bonafide reasons and compelling circumstances, that had precluded the appellant to file the appeal ... without prejudice to any other :- 1.0 On facts and circumstances of the case and in Law, Ld. CIT(A) erred in not condoning the delay in filing the penalty appeal of 740 days and ought to have considered the bonafide reasons and compelling circumstances, that had precluded the appellant

Dharmesh Girish Dixit, Mumbai vs. Income Tax Officer, WD-41(3)(1), Mumbai

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

ITA 5589/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Nov 2025AY 2018-19

Bench: Smt. Beena Pillai & Smt.Renu Jauhri

For Appellant: Mr. Jay ThakkarFor Respondent: Shri Annavaran Kosuri- Sr. AR
Section 143(3)Section 250Section 270ASection 271ASection 56Section 68Section 80C

5622/mum/2025. 1.0 On facts and circumstances of the case and in Law, Ld. CIT(A) erred in not condoning the delay in filing the penalty appeal of 722 days and ought to have considered the bonafide reasons and compelling circumstances, that had precluded the appellant to file the appeal ... without prejudice to any other :- 1.0 On facts and circumstances of the case and in Law, Ld. CIT(A) erred in not condoning the delay in filing the penalty appeal of 740 days and ought to have considered the bonafide reasons and compelling circumstances, that had precluded the appellant

Vissanji A 1 Friends Co-Operative Housing Society Ltd., Mumbai vs. ITO, Ward 20(3)(1), Mumbai

ITA 4801/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Nov 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Vishwas Mehendale (Virtually), CAFor Respondent: Smt. Smitha V. Nair, Sr. DR
Section 143(1)Section 80ASection 80P(2)(d)

appeal within the period of 30 days. He elaborated on the meaning of "sufficient cause" for the purpose of considering the petition for condonation of delay with reference to several judicial presidents in this respect. He thus, concluded that assessee had not furnished any reasonable cause which prevented it from ... there is a delay of 342 days in filing the present appeal before the Tribunal also. Assessee has placed on record, petition for condonation of delay on notarised non-judicial stamp paper dated 08.07.2025. Another affidavit is placed on record which is also notarised dated 08.10.2025. We first referee

Vissanji A 1 Friends Co-Operative Housing Society Ltd., Mumbai vs. ITO, Ward 20(3)(1), Mumbai

In the result, all the five appeals of the assessee are dismissed

ITA 4800/MUM/2025[2012-13]Status: DisposedITAT Mumbai19 Nov 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Vishwas Mehendale (Virtually), CAFor Respondent: Smt. Smitha V. Nair, Sr. DR
Section 1Section 143(1)Section 80Section 80A

appeal within the period of 30 days. He elaborated on the meaning of “sufficient cause” for the purpose of considering the petition for condonation of delay with reference to several judicial presidents in this respect. He thus, concluded that assessee had not furnished any reasonable cause which prevented it from ... there is a delay of 342 days in filing the present appeal before the Tribunal also. Assessee has placed on record, petition for condonation of delay on 6 4794, 4795,4796,4800 & 4801/MUM/2025 Vissanji A 1 Friend Co-operative Housing Society Ltd. notarised non-judicial stamp paper dated 08.07.2025. Another

Vissanji A 1 Friends Co-Operative Housing Society Ltd., Mumbai vs. ITO, Ward 20(3)(1), Mumbai

In the result, all the five appeals of the assessee are dismissed

ITA 4796/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Nov 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Vishwas Mehendale (Virtually), CAFor Respondent: Smt. Smitha V. Nair, Sr. DR
Section 1Section 143(1)Section 80Section 80A

appeal within the period of 30 days. He elaborated on the meaning of “sufficient cause” for the purpose of considering the petition for condonation of delay with reference to several judicial presidents in this respect. He thus, concluded that assessee had not furnished any reasonable cause which prevented it from ... there is a delay of 342 days in filing the present appeal before the Tribunal also. Assessee has placed on record, petition for condonation of delay on 6 4794, 4795,4796,4800 & 4801/MUM/2025 Vissanji A 1 Friend Co-operative Housing Society Ltd. notarised non-judicial stamp paper dated 08.07.2025. Another

Vissanji A 1 Friends Co-Operative Housing Society Ltd., Mumbai vs. ITO, Ward 20(3)(1), Mumbai

In the result, all the five appeals of the assessee are dismissed

ITA 4795/MUM/2025[2013-14]Status: DisposedITAT Mumbai19 Nov 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Vishwas Mehendale (Virtually), CAFor Respondent: Smt. Smitha V. Nair, Sr. DR
Section 1Section 143(1)Section 80Section 80A

appeal within the period of 30 days. He elaborated on the meaning of “sufficient cause” for the purpose of considering the petition for condonation of delay with reference to several judicial presidents in this respect. He thus, concluded that assessee had not furnished any reasonable cause which prevented it from ... there is a delay of 342 days in filing the present appeal before the Tribunal also. Assessee has placed on record, petition for condonation of delay on 6 4794, 4795,4796,4800 & 4801/MUM/2025 Vissanji A 1 Friend Co-operative Housing Society Ltd. notarised non-judicial stamp paper dated 08.07.2025. Another

Vissanji A 1 Friends Co-Operative Housing Society Ltd., Mumbai vs. ITO, Ward 20(3)(1), Mumbai

In the result, all the five appeals of the assessee are dismissed

ITA 4794/MUM/2025[2011-12]Status: DisposedITAT Mumbai19 Nov 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Vishwas Mehendale (Virtually), CAFor Respondent: Smt. Smitha V. Nair, Sr. DR
Section 1Section 143(1)Section 80Section 80A

appeal within the period of 30 days. He elaborated on the meaning of “sufficient cause” for the purpose of considering the petition for condonation of delay with reference to several judicial presidents in this respect. He thus, concluded that assessee had not furnished any reasonable cause which prevented it from ... there is a delay of 342 days in filing the present appeal before the Tribunal also. Assessee has placed on record, petition for condonation of delay on 6 4794, 4795,4796,4800 & 4801/MUM/2025 Vissanji A 1 Friend Co-operative Housing Society Ltd. notarised non-judicial stamp paper dated 08.07.2025. Another

Bharat Mukti Morcha, New Delhi vs. CIT (Exemption) Delhi, New Delhi

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

ITA 963/DEL/2025[2024-2025]Status: DisposedITAT Delhi19 Nov 2025AY 2024-2025

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwal

Section 12ASection 2(15)Section 80G

pertaining to A.Y. 2024-25 These appeals are filed time barred by 295 days. The 2. assessee has filed the applications for condonation of delay for 295 days. In the application the assessee has stated that due to illness he has not filed the appeal within prescribed time limit ... assessee has shown sufficient cause for not filing the appeal within time limit. Therefore, we allow the application for condonation of delay. Delay is condoned and appeals are admitted for adjudication. 3. The assessee has raised following grounds of appeal in ITA No. 963/Del/2025:- 1.Erroneous Rejection of Application under Section

Bharat Mukti Morcha, Delhi vs. CIT(Exemption), New Delhi

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

ITA 962/DEL/2025[2024-2025]Status: DisposedITAT Delhi19 Nov 2025AY 2024-2025

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwal

Section 12ASection 2(15)Section 80G

pertaining to A.Y. 2024-25 These appeals are filed time barred by 295 days. The 2. assessee has filed the applications for condonation of delay for 295 days. In the application the assessee has stated that due to illness he has not filed the appeal within prescribed time limit ... assessee has shown sufficient cause for not filing the appeal within time limit. Therefore, we allow the application for condonation of delay. Delay is condoned and appeals are admitted for adjudication. 3. The assessee has raised following grounds of appeal in ITA No. 963/Del/2025:- 1.Erroneous Rejection of Application under Section

Neha Gupta, Haryana vs. ITO Ward-3(1), Gurugram, Haryana

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

ITA 4822/DEL/2025[2011-12]Status: DisposedITAT Delhi19 Nov 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Krinwant Sahay, Accountnat Member [Assessment Year: 2011-12]

Section 144Section 271(1)(c)

that there is delay of 415 days in filing of the present appeal before the Tribunal. The assessee has filed application for condonation of delay. 3.1. In the condonation application, it has been pointed out that the assessee Mrs. Neha Gupta, was suffering from serious medical ailments since