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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

Chandrashekhar Dinkar Chavan, Mumbai vs. Assessment Unit, Mumbai

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

ITA 2193/MUM/2025[2017-18]Status: DisposedITAT Mumbai22 Jul 2025AY 2017-18

Bench: Shri Pawan Singh(Physical Hearing) Chandrashekhar Dinkar Chavan Ito, Ward-27(1)(1), Room No. 3667, Bldg. No. 105, Vs Vashi Rly. Station Commercial Near Hanuman Temple, Tilak Nagar, Complex, 406, Tower-5, Vashi, Chembur,Mumbai-400089. Navi Mumbai, [Pan No. Acipc1075B] Maharashtra-400703 Appellant / Assessee Respondent / Revenue

Section 145Section 234ASection 254(1)Section 28Section 69A

learned Senior Departmental Representative (ld. Sr. DR) for the revenue opposed to the plea of ld. AR of the assessee for seeking condonation of delay. The ld. Sr. DR for the revenue submits that assessee has not explained cause of delay in proper manner. The cause of delay explained ... belatedly appeals can only be condoned when sufficient reason is shown. The assessee must explained each day’s delay. Thus, plea of condonation of delay raised by assessee is liable to be rejected. The ld. Sr. DR, further submits that assessee is habitual defaulter in not attending the proceeding before

Pravinkumar Harishchandra Choudhary, Mumbai vs. ITO 24(3)(1), Mumbai

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

ITA 1412/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Jul 2025AY 2018-19

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankarpravinkumar Harishchandra Vs. Ito – 24(3)(1) Choudhary Piramal Chamber 102, Hill Queen Apartment Mumbai Marol, Maroshi Road, Bahvani Nagar, Andheri (E) Pan/Gir No. Aatpc0999D (Applicant) (Respondent)

Section 143(3)Section 250Section 5

present appeal filed by the assessee is time barred and in this regard an 2 Pravinkumar Harishchandra Choudhary., Mumbai. affidavit for seeking condonation of delay has been filed by the assessee, wherein it has been mentioned as under: 1, Mr. PRAVINKUMAR HARISHCHANDRA CHOUDHARY having premises at 102, HILL QUEEN APARTMENT ... reasons totally beyond our control. Looking at the above facts the necessary steps could not be taken, please take a lenient view and condone the delay. 2. This delay is wholly unintentional & beyond the control of the appellant. The word 'Sufficient cause' has been construed quite liberally in case

Bhatia Medicos, Jalandhar vs. Income Tax Officer Ward-(3)1_, Jalandhar

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

ITA 688/ASR/2024[2017-2018]Status: DisposedITAT Amritsar21 Jul 2025AY 2017-2018

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Sudhir Sehgal & Sh. Anil Miglani, Adv
Section 115BSection 142(1)Section 144Section 250Section 69A

Ward-3(1), Jalandhar dated 16.12.2019 passed u/s 144 of the I.T. Act, 1961. 2 I.T.A. No. 688/Asr/2024 Assessment Year: 2017-18 Condonation of delay:- It is pointed out by the registry that the appeal was 2. belatedly filed by 291 days, the application for condonation of delay has been ... willful default on his part. 3. The ld. DR has no objection. Considering the facts and reasons pointed out in the affidavit, we condone the delay and admit the appeal for hearing on merits. 4. Grounds of appeal taken by the assessee in Form No. 36 are as follows

Juzar Mohammed Husain Bankodawala, Jaipur vs. Circle (Intl Tax), Jaipur

ITA 575/JPR/2025[2017-18]Status: DisposedITAT Jaipur21 Jul 2025AY 2017-18

Bench: SHRIGAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: NoneFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 142(1)Section 147Section 148Section 250Section 69

that there were deficiencies in the appeal, which the appellant did not remove, and furthermore, the appellant did not move any application seeking condonation of delay of about 5 months in filing of the appeal before Learned CIT(A), and as such, CIT(A) was justified in dismissing the appeal

Sh. Abhay Kumar Godha, Jaipur vs. ACIT, Circle-1, Jaipur

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

ITA 546/JPR/2025[2017-18]Status: DisposedITAT Jaipur21 Jul 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं./ITA No. 546/JPR/2025 निर्धारण वर्ष / Assessment Year : 2017-18 Shri Abhay Kumar Godha 750, Achariyon Ka Rasta, Kishan Pole Bazar Jaipur - 303 003 (Raj) बनाम Vs. The ACIT Circle-1 Jaipur प्रत्यर्थी / Respondent स्थायी लेखा सं. / जी.आई.आर. सं./PAN/GIR No.: AAPPG 4721K अपीलार्थी / Appellant निर्धारिती की ओर से / Assessee by : Shri P.C. Parwal, CA राजस्व की ओर से / Revenue by: Shri Gaurav Awasthi, JCIT-DR स

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Gaurav Awasthi, JCIT-DR
Section 115BSection 250Section 36(1)(va)Section 69A

delay of 340 days in filing the appeal for which the assessee has filed an application dated 03-04-2025 for condonation of delay giving therein following reasoning. ‘’Sub: Application for condonation of delay in filing the appeal With reference to above it is to submit that ... CIRCLE-1, JAIPUR downloaded from my e-filing portal and it was suggested to me to file appeal before ITAT with application for condonation of delay. 4. Thus from the date of the order u/s 250, the time for filing the appeal before ITAT has expired but from the date

Helping 23 Wings Foundation, Jaipur vs. CIT (Exemption), Jaipur

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

ITA 530/JPR/2025[2024-25]Status: DisposedITAT Jaipur21 Jul 2025AY 2024-25

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Kapil Banthia, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 12ASection 80G

each appeals of the assessee i.e. 12AB and 80G of the Act, for which the Director of the Foundation filed an application for condonation of delay with following reasoning: - HELPING 23 WINGS FOUNDATION VS CIT (E), JAIPUR 1. The signed documents were timely prepared and dispatched by the foundation ... compliance with statutory requirements. In view of the facts mentioned above and in the interest of justice, we humbly request your Honour to condone the delay in filing the appeal and allow the same to be considered on merits. The affidavits affirming the facts is also filed with the application

Helping 23 Wings Foundation, Jaipur vs. CIT (Exemption), Jaipur

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

ITA 529/JPR/2025[2024-25]Status: DisposedITAT Jaipur21 Jul 2025AY 2024-25

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Kapil Banthia, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 12ASection 80G

each appeals of the assessee i.e. 12AB and 80G of the Act, for which the Director of the Foundation filed an application for condonation of delay with following reasoning: - HELPING 23 WINGS FOUNDATION VS CIT (E), JAIPUR 1. The signed documents were timely prepared and dispatched by the foundation ... compliance with statutory requirements. In view of the facts mentioned above and in the interest of justice, we humbly request your Honour to condone the delay in filing the appeal and allow the same to be considered on merits. The affidavits affirming the facts is also filed with the application

Nokari Samabay Krishi Unnayan Samity Ltd., Nadia vs. ITO, Ward 41(3), Nadia

ITA 563/KOL/2025[2018-2019]Status: DisposedITAT Kolkata21 Jul 2025AY 2018-2019

Bench: the Hon'ble Tribunal. Along with Form No.

Section 250Section 270A

suffering from illness. 6. That the deponent to be filed the appeal on 21.03.2025 along-with medical certificates and a prayer for condonation of delay. 7. That in this way there is a delay of 397days for which a prayer for condonation of delay was filed. 8. That delay ... affidavit filed for ITA No. 562/Kol/2025, we hereby condone the said delay. It is noticed that there is an application for condoning the delay in ITA No. 563/Kol/2025 also, which is as under: “We write with reference to the appeal for the captioned assessment year which has been preferred

Nokari Samabay Krishi Unnayan Samity Ltd., Nadia vs. ITO, Ward 41(3), Nadia

ITA 562/KOL/2025[2018-2019]Status: DisposedITAT Kolkata21 Jul 2025AY 2018-2019

Bench: the Hon'ble Tribunal. Along with Form No.

Section 250Section 270A

suffering from illness. 6. That the deponent to be filed the appeal on 21.03.2025 along-with medical certificates and a prayer for condonation of delay. 7. That in this way there is a delay of 397days for which a prayer for condonation of delay was filed. 8. That delay ... affidavit filed for ITA No. 562/Kol/2025, we hereby condone the said delay. It is noticed that there is an application for condoning the delay in ITA No. 563/Kol/2025 also, which is as under: “We write with reference to the appeal for the captioned assessment year which has been preferred

Vikramathithan Selvakumaran Raja, Madurai vs. ACIT, Ncc-1, Madurai

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

ITA 985/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Jul 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:985/Chny/2025 िनधा"रण वष" / Assessment Year: 2017-18 Vikramathithan Selvakumaran The Assistant Commissioner Of Raja, Vs. Income Tax, 61/1C, T B Road, Mahaboopalayam, Non-Corp. Circle -1, Madurai – 625 016. Madurai – 625 002. [Pan:Auvps-0301-B] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri. R. Thulsi Ram, Advocate &For Respondent: Shri. Kumar Chandan, J.C.I.T
Section 143(2)Section 68

outset, we find that there is a delay of 613 days in appeal filed by the assessee, for which, a petition for condonation of delay in filing of the appeal along with Affidavit explaining the reasons for delay, has been filed by the assessee. The ld.AR submitted that the delay

Tvisha Capital Investments Consultancy Private Limited, Chennai vs. The Income Tax Officer, Corporate Ward 3(1), Chennai

ITA 1590/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Jul 2025AY 2018-19

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 1586, 1587, 1588, 1589 & 1590/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19

For Appellant: Shri R.S. Lakshmi NarayanaFor Respondent: Shri AR.V. Sreenivasan, CIT
Section 250

submitted the reasons for delay. The FAA has noted that though the assessee in Form 35 has stated that the reasons for condonation of delay and supporting documentary evidence will be furnished during the course of hearing, no application has been filed for condonation of delay and therefore, the appeals

Tvisha Capital Investments Consultancy Private Limited, Chennai vs. The Income Tax Officer, Corporate Ward 3(1), Chennai

ITA 1589/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Jul 2025AY 2018-19

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 1586, 1587, 1588, 1589 & 1590/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19

For Appellant: Shri R.S. Lakshmi NarayanaFor Respondent: Shri AR.V. Sreenivasan, CIT
Section 250

submitted the reasons for delay. The FAA has noted that though the assessee in Form 35 has stated that the reasons for condonation of delay and supporting documentary evidence will be furnished during the course of hearing, no application has been filed for condonation of delay and therefore, the appeals

Tvisha Capital Investments Consultancy Private Limited, Chennai vs. The Income Tax Officer, Corporate Ward 3(1), Chennai

ITA 1588/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Jul 2025AY 2018-19

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 1586, 1587, 1588, 1589 & 1590/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19

For Appellant: Shri R.S. Lakshmi NarayanaFor Respondent: Shri AR.V. Sreenivasan, CIT
Section 250

submitted the reasons for delay. The FAA has noted that though the assessee in Form 35 has stated that the reasons for condonation of delay and supporting documentary evidence will be furnished during the course of hearing, no application has been filed for condonation of delay and therefore, the appeals

Tvisha Capital Investments Consultancy Private Limited, Chennai vs. The Income Tax Officer, Corporate Ward 3(1), Chennai

ITA 1587/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Jul 2025AY 2017-18

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 1586, 1587, 1588, 1589 & 1590/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19

For Appellant: Shri R.S. Lakshmi NarayanaFor Respondent: Shri AR.V. Sreenivasan, CIT
Section 250

submitted the reasons for delay. The FAA has noted that though the assessee in Form 35 has stated that the reasons for condonation of delay and supporting documentary evidence will be furnished during the course of hearing, no application has been filed for condonation of delay and therefore, the appeals

Tvisha Capital Investments Consultancy Private Limited, Chennai vs. The Income Tax Officer, Corporate Ward 3(1), Chennai

ITA 1586/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Jul 2025AY 2017-18

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 1586, 1587, 1588, 1589 & 1590/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19

For Appellant: Shri R.S. Lakshmi NarayanaFor Respondent: Shri AR.V. Sreenivasan, CIT
Section 250

submitted the reasons for delay. The FAA has noted that though the assessee in Form 35 has stated that the reasons for condonation of delay and supporting documentary evidence will be furnished during the course of hearing, no application has been filed for condonation of delay and therefore, the appeals

Balasubramanian Saravanan, Chennai vs. ITO, Ncw-17(7), Chennai

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

ITA 1498/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Jul 2025AY 2017-18

Bench: Shri George George Kand Shri S.R. Raghunatha

For Appellant: Shri Abhishek Murali, CAFor Respondent: Shri AR. V. Sreenivasan, CIT
Section 119(2)(b)Section 139(1)Section 143(1)Section 250Section 90

There is a delay of 360 days in filing the appeal. The assessee has filed a petition for condonation of delay and affidavit stating there in the reasons for belated filing of this appeal. The reason stated is that the assessee was pursuing alternative remedy for condonation of delay ... days. On perusal of the same, we find there is sufficient cause for delay in filing this appeal before the Tribunal. Hence, we condone the delay in filing the appeal and proceed to dispose off the appeal on merits. 3. Brief facts of the case are as follows: The assessee

N.S. Sivaraj, Gobchettipalayam vs. ITO, Ward-2(1), Erode

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

ITA 1342/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Jul 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.1342/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 V. N.S. Sivaraj, The Ito, 485/A3, Sri Bannariamman Industry, Ward-2(1), Nadhipalayam, Kullampalayam Po, Erode. Gobichettipalayam-638 476. [Pan: Apnps 0117 A] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr. N.C. Ravikrishna, Advocate : ""यथ" क" ओर से /Respondent By Ms. Gauthami Manivasagam, Jcit : सुनवाईक"तारीख/Date Of Hearing 15.07.2025 : घोषणाक"तारीख /Date Of Pronouncement 21.07.2025

Section 142Section 144Section 147Section 154Section 234A

levy of interest u/s.234A dated 29.11.2023. However, the ld. CIT(A) dismissed the appeal on the ground of rejection of petition for condonation of delay. There was ‘825’ days delay in filing the appeal. In this regard, assessee N.S. Sivaraj :: 3 :: has filed Medical Certificate stating that he had infected ... view that the delay in filing appeal before the ld.CIT(A) is a sufficient cause. Hence, we direct the ld.CIT(A) to condone the delay in filing appeal and hear the appeal on merits. Needless to say, that the ld.CIT(A) will follow the principle of natural justice and grant

Dd122 Harur & Pr Patti Tk Ghss &Ghs Employees Co-Op. Thrift & Credit Society, Dharmapuri vs. The Income Tax Officer, Ward-1, Dharmapuri

In the result, the appeal filed by the assessee in ITA

ITA 1333/CHNY/2025[2022-23]Status: DisposedITAT Chennai21 Jul 2025AY 2022-23

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.1333/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 V. Dd 122 Harur & Pr Patti Tk Ghss & The Ito, Ghs Employees Co-Op. Thrift & Ward-1, Credit Society, Dharmapuri. 1/16,Kanikaran Kottai, Sikkampatti V. Muthampatti Veppilaimithempatti, Dharmapuri-636 903. [Pan: Aadah 1485 L] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca ""यथ" क" ओर से /Respondent By : Ms. Gauthami Manivasagam, Jcit सुनवाईक"तारीख/Date Of Hearing : 15.07.2025 : घोषणाक"तारीख /Date Of Pronouncement 21.07.2025

For Appellant: Mr.T.S. LakshmiFor Respondent: Ms. Gauthami Manivasagam
Section 119(2)Section 139(1)Section 143(1)Section 250Section 80P

delay occurred due to getting the accounts audited under the respective State Laws, the same could be taken as a valid reason for condoning the delay. 5. In view of the above grounds and other submissions to be made at the time of Appeal hearing, the order U/S 250 passed ... assessee has submitted that the assessee has filed a condonation petition 13.07.2025 before the CBDT under section 119(2) of the Act to condone the delay in filing the return of income u/s 139(1). 6. We have heard the rival submissions, perused the materials available on record and gone

Manikarnike Yadu, Bengaluru vs. Income Tax Officer, Ward-3(2)(1), Bengaluru

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

ITA 276/BANG/2025[2010-11]Status: DisposedITAT Bangalore21 Jul 2025AY 2010-11

Bench: Shri Prashant Maharishiassessment Year : 2010-11

For Appellant: Shri Abhilash, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Revenue
Section 142(1)Section 144Section 148Section 156

purchase of property on 6.7.2012 and therefore even the addition on merit is not correct. It was further stated that along with condonation of delay request, the assessee also submitted on the merits of the case. The ld. CIT(A) did not consider that the delay in filing ... sufficient cause. 8. The ld. DR submitted that there is no fault with the order of the ld. CIT(A) in not condoning the delay of 150 days as there was no sufficient cause shown by the assessee. Page 5 of 7 9. We have carefully considered the rival contentions

Hydroair Tectonics Pcd Limited, Mumbai vs. Dy. CIT Central Circle 2(1), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 1931/MUM/2025[2018-19]Status: DisposedITAT Mumbai21 Jul 2025AY 2018-19

Bench: Shri Saktijit Dey & Shri Prabhash Shankarhydroair Tectonics Pcd V/S. Dy. Commissioner Of Income Limited, 501, Concord बनाम Tax, Central Circle – 2(1), Premises Co-Op Society Ltd., Room No. 804, Pratishtha Plot No. 66A, Sector 11, Cbd Bhavan, Maharishi Karve Belapur –400 614, Road, Mumbai –400 020, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach9686C Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri Subhash Kumar Kedia, ARFor Respondent: Shri Hemanshu Joshi, (Sr. DR)
Section 144Section 270ASection 40

restoring the penalty proceedings to the ld.CIT(A).It is also intimated that the quantum appeal has been already restored to him after condonation of delay by the hon’ble ITAT vide order in ITA No.1853/Mum/2025 dated 02.07.2025. 5. In respect of the delay, it is submitted ... took immediate steps to file an appeal as soon as he came to know about the assessment order. It is requested to condone the delay in filing of appeal It is also assured that such delays will not occur in the future