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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

Shriram Paropkari Trust, Jaipur vs. CIT Exemption, Jaipur

In the result, the appeals of the assessee in ITA No

ITA 339/JPR/2025[2025-26]Status: DisposedITAT Jaipur19 May 2025AY 2025-26

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 12ASection 80G

hearing of the appeals it is noted both the appeals were filed with a delay of 33 days. The assessee prayed to condone the delay in filling the appeal by a separate prayer dated 27.02.2025 which reads as follows : Shriram Paropkari Trust vs. CIT Sub: Prayer for condonation of Delay ... approaching the courts belatedly. It is not the length of delay that would be required to be considered while examining the plea for condonation of delay, it is the cause for delay which has been propounded will have to be examined. If the cause for delay would fall within

Shriram Paropkari Trust, Jaipur vs. CIT Exemption, Jaipur

In the result, the appeals of the assessee in ITA No

ITA 338/JPR/2025[2025-26]Status: DisposedITAT Jaipur19 May 2025AY 2025-26

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 12ASection 80G

hearing of the appeals it is noted both the appeals were filed with a delay of 33 days. The assessee prayed to condone the delay in filling the appeal by a separate prayer dated 27.02.2025 which reads as follows : Shriram Paropkari Trust vs. CIT Sub: Prayer for condonation of Delay ... approaching the courts belatedly. It is not the length of delay that would be required to be considered while examining the plea for condonation of delay, it is the cause for delay which has been propounded will have to be examined. If the cause for delay would fall within

Subhash Pareta, Kota Rajasthan vs. ACIT, Circle-2, Kota, Kota Rajashtan

In the result, the appeal of the assessee is dismissed

ITA 114/JPR/2025[2011-12]Status: DisposedITAT Jaipur19 May 2025AY 2011-12

Bench: Shri Gagan Goyal & Shri Narinder Kumarsubhash Pareta, 3/148, Basant Vihar, Dada Bari, Ganesh Talab, Kota - 324009 Pan No. Aggpp4046H ...... Appellant Vs.

For Appellant: Mr.P.C. PARWAL, CA, Ld. ARFor Respondent: Mrs. ANITA RINESH, Addl. CIT, Ld. Sr. DR
Section 142Section 250Section 40ASection 69Section 69C

assessee has raised the following grounds of appeal: 1. That the Ld. CIT(A) grossly erred in rejecting the application for condonation of delay in filling of appeal though the appellant filed reasons etc. 2. That the Ld. A.O. grossly erred on Law and Facts in making disallowance

Deputy Commissioner of Income Tax, Central Circle - 1(1), Kolkata vs. Biswanath Hosiery Mills Ltd., Kolkata

In the result, appeal of the revenue stands dismissed

ITA 1225/KOL/2024[2015-16]Status: DisposedITAT Kolkata19 May 2025AY 2015-16

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI SANJAY AWASTHI (Accountant Member)

For Appellant: Ms. Bhawna Banthia, CAFor Respondent: Ms. Roma Chaudhury, Sr. DR

appeal of the revenue is barred by 81 days. In this regard, the revenue has filed an application for condonation of delay stating therein sufficient reasons, which are plausible and not found to be false. Accordingly, we condone the delay of 81 days in filing the present appeal

Aa533 Umareddiyur Primary Agricultural Cooperative Credit Society Limited, Erode vs. Income Tax Officer, Ward 2(1) Erode, Erode

ITA 2784/CHNY/2024[2016-17]Status: DisposedITAT Chennai19 May 2025AY 2016-17

Bench: Shri George George K & Shri Jagadish

For Appellant: Ms. A. Vijayalakshmi, CAFor Respondent: Ms. Anitha, Addl.CIT
Section 143(2)Section 143(3)Section 250Section 80Section 80PSection 80P(2)(a)Section 80P(2)(d)

Year is 2016-17. 2. There is a delay of 32 days in filing this appeal. The assessee has filed a petition for condonation of delay. On perusal of the reasons stated in the condonation application, we are satisfied that there is sufficient cause for delay in filing this appeal ... latches can be attributed to the assessee. Hence, we condone the delay of 32 days in filing the appeal and proceed to dispose off the appeal on merits. 3. The grounds raised reads as follows:- Ground No.1 The Assessing officer and CIT(A) is contrary to law, facts and circumstances

ACIT-CC-7(3), Mumbai vs. Lotus Grih Nirman Private Limited, Mumbai

In the result, appeal of the revenue is dismissed whereas cross-objection of the assessee is allowed

ITA 1484/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 May 2025AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18 Acit, Cc-7(3), Mumbai M/S Lotus Grih Nirman Pvt Ltd. Room No. 655, Floor 6Th, 1201,12Th Floor Lotus Link Square, Aayakar Bhavan, M.K.Road, Vs. Near Apna Bazar, D N Nagar, New Mumbai-4000202 Link Road, Andheri West, Mumbai- 400 053 Pan No. Aabcl 0864 D Appellant Respondent Co No. 105/Mum/2025 (Arising Out Of Ita No. 1484/Mum/2025) Assessment Year: 2017-18 M/S Lotus Grih Nirman Pvt Ltd. Acit, Cc-7(3), Mumbai 1201,12Th Floor Lotus Link Room No. 655, Floor 6Th, Aayakar Square, Near Apna Bazar, D N Vs. Bhavan, M.K.Road, Nagar, New Link Road, Andheri Mumbai-4000202 West, Mumbai- 400 053 Pan No. Aabcl 0864 D Appellant Respondent

For Appellant: Mr. Niraj SoniFor Respondent: Mr. Ram Krishn Kedia, CIT-DR
Section 148Section 148ASection 151

inadvertently it was mentioned as received on 31.12.2024. 2. We have heard the rival submissions of the parties on the issue of condonation of delay in the filing of the cross-objection by the assessee. The assessee has explained that the delay occurred due to an inadvertent error in Form ... 1484/MUM/2024 & CO No. 105/MUM/2025 filing the cross objection. Considering the explanation offered by the assessee and small period of 19 days , we condoned the delay and cross objection is admitted for adjudication." 3. Learned counsel for the assessee invited our attention to the cross-objection and submitted that the issues

Percival Joseph Pereira, Mumbai vs. Income Tax Officer (It) -3(3)(1), Mumbai

In the result, both the appeals by the assessee are allowed

ITA 4662/MUM/2024[2016-17]Status: DisposedITAT Mumbai19 May 2025AY 2016-17

Bench: Amit Shukla & Shri Girish Agrawal

Section 143(3)Section 271(1)(c)Section 45(5)(b)Section 56Section 56(2)(viii)

hence penalty u/s 271(1)(c) of Rs 20,10,01,733/- may be deleted.” 1) The Ld CIT(A) erred in not condoning the delay in filing appeal with appreciating that Assessee had shown sufficient cause for delay and hence the delay in filing the appeal before ... first instance took note of delay of 1119 days in filing the appeal by the assessee before him. Assessee furnished an application for condonation of delay in filing the said appeal explaining the reasons for the same. Ld. CIT(A) took note of the reasons given by the assessee

Percival Joseph Pereira, Mumbai vs. Income Tax Officer (It)-3(3)(1), Mumbai

In the result, both the appeals by the assessee are allowed

ITA 4661/MUM/2024[2016-17]Status: DisposedITAT Mumbai19 May 2025AY 2016-17

Bench: Amit Shukla & Shri Girish Agrawal

Section 143(3)Section 271(1)(c)Section 45(5)(b)Section 56Section 56(2)(viii)

hence penalty u/s 271(1)(c) of Rs 20,10,01,733/- may be deleted.” 1) The Ld CIT(A) erred in not condoning the delay in filing appeal with appreciating that Assessee had shown sufficient cause for delay and hence the delay in filing the appeal before ... first instance took note of delay of 1119 days in filing the appeal by the assessee before him. Assessee furnished an application for condonation of delay in filing the said appeal explaining the reasons for the same. Ld. CIT(A) took note of the reasons given by the assessee

Saneev Chawla, Ghaziabad vs. ITO, Ward-2(2)(4), Ghaziabad

In the result, appeal of the assessee is partly allowed in the terms aforesaid

ITA 1082/DEL/2025[2012-13]Status: DisposedITAT Delhi19 May 2025AY 2012-13

Bench: Shri Vikas Awasthyआअसं.1082/िद"ी/2025(िन.व. 2012-13) Sanjeev Chawla, S/O Shri Krishan Lal Chawla, H.No. 286, Vivekanand Nagar, Ghaziabad, Up 201002 ...... अपीलाथ"/Appellant Pan: Amvpc-4308-G बनाम Vs. Income Tax Officer, Ward-2(2)(4), Cgo Complex-I, Purani Hapur Chungi, ..... "ितवादी/Respondent Ghaziabad, Up 201002 अपीलाथ" "ारा/ Appellant By : S/Shri Sahil Sharma & Sanjeev Prashar, Advocates "ितवादी"ारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 19/05/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 19/05/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 20.03.2024, For Assessment Year 2012-13. 2. The Appeal Is Time Barred By 270 Days. The Assessee Has Filed A Petition For Condonation Of Delay Supported By Medical Certificate. After Perusal Of Same, I Am Satisfied That Delay In Filing Of Appeal Is Not Intentional, But Is For The Reasons Stated In The Condonation Petition Which Appears To Be Bonafide. Hence, Delay In Filing Of Appeal Is Condoned & Appeal Is Admitted For Hearing On Merits.

For Appellant: S/Shri Sahil Sharma & Sanjeev Prashar, AdvocatesFor Respondent: Shri Manoj Kumar, Sr. DR
Section 44ASection 69A

dated 20.03.2024, for assessment year 2012-13. 2. The appeal is time barred by 270 days. The assessee has filed a petition for condonation of delay supported by Medical Certificate. After perusal of same, I am satisfied that delay in filing of appeal is not intentional

Faridabad Educational Society, Near Ntpc Mujedi Road vs. Income Tax Officer Exemptions Ward, Exemptions Ward Faridabad

In the result, Appeal of the Assessee in ITA Nos

ITA 874/DEL/2024[2017-18]Status: DisposedITAT Delhi19 May 2025AY 2017-18

Bench: Shri M. Balaganesh & Sh. Yogesh Kumar U.S.Ita No. 874/Del/2024 (A.Y 2017-18)

verifying the material on record. 3. There is a delay of 64 days in filing the above appeals. The Assessee filed application for condonation of delay contending that the notices issued by the Ld. CIT(A) have been over looked/ignored by the employee of the appellant, therefore, there ... delay in filing the captioned appeals. For the reasons stated in the application for condonation of delay, the delay of 63 days in filing the present Appeals hereby condoned. 4. Heard, the Department's Representative. The Ld. CIT(A) passed the order impugned for both Assessment Year

Faridabad Educational Society, Faridabad vs. Income Tax Officer Exemption, Faridabad

In the result, Appeal of the Assessee in ITA Nos

ITA 873/DEL/2024[2012-13]Status: DisposedITAT Delhi19 May 2025AY 2012-13

Bench: Shri M. Balaganesh & Sh. Yogesh Kumar U.S.Ita No. 874/Del/2024 (A.Y 2017-18)

verifying the material on record. 3. There is a delay of 64 days in filing the above appeals. The Assessee filed application for condonation of delay contending that the notices issued by the Ld. CIT(A) have been over looked/ignored by the employee of the appellant, therefore, there ... delay in filing the captioned appeals. For the reasons stated in the application for condonation of delay, the delay of 63 days in filing the present Appeals hereby condoned. 4. Heard, the Department's Representative. The Ld. CIT(A) passed the order impugned for both Assessment Year

Brijesh Kumar Pandey, Dubal Story vs. JCIT (A)-13 Mumbai, Mumbai

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

ITA 4437/MUM/2024[2018-19]Status: DisposedITAT Delhi19 May 2025AY 2018-19

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S.RIFAUR RAHMAN (Accountant Member)

For Appellant: NoneFor Respondent: Shri Rajesh Tiwari, Sr. DR
Section 143(1)Section 43B

days before the first appellate authority. We observe that ld. CIT (A) has not given opportunity to the assessee and also not condoned the delay and dismissed the appeal of the assessee in limine. 4. Ld. DR of the Revenue submitted that opportunity was given to the assessee to file ... doubt, assessee has filed the appeal before the First Appellate Authority with the huge delay. However, assessee was not able to file the condonation of delay along with reasons for delay with documentary evidences. After due consideration and merit in the statement of facts/submissions of the assessee on record

Medsave Health Insurance Tpa Limited, New Delhi vs. ACIT, CPC TDS, Ghaziabad

In the result, all the four appeals of the assessee are allowed

ITA 1028/DEL/2022[2014-15]Status: DisposedITAT Delhi19 May 2025AY 2014-15

Bench: Shri Shamim Yahya & Shri Vimal Kumar

For Appellant: Shri Sahil Sharma, AdvFor Respondent: Shri Arvind Bansal, Sr. DR
Section 154Section 200ASection 3

decided by this common order. 3. Learned Authorized Representative for the appellant/assessee submitted that the Ld.CIT(A) erred in dismissing the applications for condonation of delay in filing appeals as well as appeal on merit illegally. He submitted that Ld.CIT(A) failed to appreciate that the delay in filing appeals ... year 2 months 6 days 6. Keeping in view the aforesaid details, Ld.CIT(A) vide his order dated 23.03.2022 dismissed the applications for condonation of delay in filing appeals as well as appeals were dismissed on merit. Ld.CIT(A) erred in dealing with appeals on merit without condoning the delay

Medsave Health Insurance Tpa Limited, Delhi vs. ACIT, CPC TDS, Ghaziabad

In the result, all the four appeals of the assessee are allowed

ITA 1015/DEL/2022[2018-19]Status: DisposedITAT Delhi19 May 2025AY 2018-19

Bench: Shri Shamim Yahya & Shri Vimal Kumar

For Appellant: Shri Sahil Sharma, AdvFor Respondent: Shri Arvind Bansal, Sr. DR
Section 154Section 200ASection 3

decided by this common order. 3. Learned Authorized Representative for the appellant/assessee submitted that the Ld.CIT(A) erred in dismissing the applications for condonation of delay in filing appeals as well as appeal on merit illegally. He submitted that Ld.CIT(A) failed to appreciate that the delay in filing appeals ... year 2 months 6 days 6. Keeping in view the aforesaid details, Ld.CIT(A) vide his order dated 23.03.2022 dismissed the applications for condonation of delay in filing appeals as well as appeals were dismissed on merit. Ld.CIT(A) erred in dealing with appeals on merit without condoning the delay

Medsave Health Insurance Tpa Limited, Delhi vs. ACIT, CPC TDS, Ghaziabad

In the result, all the four appeals of the assessee are allowed

ITA 1014/DEL/2022[2017-18]Status: DisposedITAT Delhi19 May 2025AY 2017-18

Bench: Shri Shamim Yahya & Shri Vimal Kumar

For Appellant: Shri Sahil Sharma, AdvFor Respondent: Shri Arvind Bansal, Sr. DR
Section 154Section 200ASection 3

decided by this common order. 3. Learned Authorized Representative for the appellant/assessee submitted that the Ld.CIT(A) erred in dismissing the applications for condonation of delay in filing appeals as well as appeal on merit illegally. He submitted that Ld.CIT(A) failed to appreciate that the delay in filing appeals ... year 2 months 6 days 6. Keeping in view the aforesaid details, Ld.CIT(A) vide his order dated 23.03.2022 dismissed the applications for condonation of delay in filing appeals as well as appeals were dismissed on merit. Ld.CIT(A) erred in dealing with appeals on merit without condoning the delay

Bhartiya Shiksha Sammittee Kashi Pradesh, Allahabad vs. Dc/ACIT-2(CPC), Allahabad

In the result, the appeal of the assessee is dismissed

ITA 182/ALLD/2024[2015-16]Status: DisposedITAT Allahabad16 May 2025AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 11Section 12ASection 12A(2)Section 143(1)Section 253(3)

been filed by the assessee, beyond time limit prescribed under section 253(3) of IT Act. The assessee has submitted application for condonation of delay in filing of the appeal; I.T.A. No.182/Alld/2024 Assessment Year:2015-16 3 pleading that the delay was unintentional and beyond the control of the assessee ... admit the appeal for hearing. The learned Sr. Departmental Representative for Revenue did not express any objection to assessee’s application for condonation of delay in filing of the appeal. In view of the foregoing, and in specific facts and circumstances of the present appeal before us, the delay

Shree Jamnagar Jilla Sahakari Kharid Vechan Sangh Limited, Jamnagar vs. DCIT-Cir-2(1), Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 223/RJT/2025[2018-2019]Status: DisposedITAT Rajkot16 May 2025AY 2018-2019

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.223/Rjt/2025 "नधा"रण वष"/Assessment Year : 2018-19

For Appellant: Ms. Janvi Shah, ARFor Respondent: Shri Dheeraj Kumr Gupta, Sr-DR
Section 142(1)Section 144Section 250Section 80P(2)(d)

such facts are as recorded in para-5.1 to 5.6 of impugned order by ld CIT(A). The ld CIT(A) not condoned the delay by taking view that no documentary evidence is filed by the assessee. The Ld. Counsel of the assessee prayed for condonation of delay in filing ... medical ground of tax consultant. 4. On the other hand, learned DR for the revenue, opposed the prayer of the assessee for condonation of delay before the Ld. CIT(A). 5. I have heard both the parties on this preliminary issue. I note that the reasons given in the affidavit

Vinodbhai Ravjibhai Sakhiya, Rajkot vs. ITO, Ward-1(2)(2), Rajkot

In the result, ground raised by the assessee is allowed for statistical purposes

ITA 182/RJT/2025[2011-12]Status: DisposedITAT Rajkot16 May 2025AY 2011-12

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.182/Rjt/2025 "नधा"रण वष"/Assessment Year : 2011-12 Vinod Ravjibhai Sakhiya, Income Tax Officer, बनाम/ Shivam, 4-Radha Nagar, B/H. Ward-1(2)(2), Rajkot, Aayakar Vs Laxmi Nagar, Rajkot-360 004 Bhavan, Race Course, Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Blqps 0262 N (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ar राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Sr-Dr

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Dheeraj Kumr Gupta, Sr-DR
Section 144Section 250

appeal filed by the assessee, before the Tribunal is barred by limitation of 386 days. The assessee moved an affidavit and petition for condonation of delay, requesting the Bench to condone the delay. The Ld. Counsel for the assessee explained the sufficient cause stating that tax ITA No. 182/Rjt/2025 ... justice and matter, may be adjudicated on merit. 3. However, Ld. Senior DR for the Revenue opposed the prayer of assessee for condonation of delay and stated that delay should not be condoned, on the ground that it was the mistake of the assessee`s, tax consultant. 4. I have

Kandalloor Service Co-Operative Bank Limited No2166, Alappuzha vs. Income Tax Officer, Alappuzha

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

ITA 234/COCH/2025[2017-18]Status: DisposedITAT Cochin16 May 2025AY 2017-18

Bench: Shri George George K, Vice- & Shri Inturi Rama Rao

For Appellant: Sri.R.Krishnan, CAFor Respondent: Smt.Leena Lal, Senior AR
Section 139(1)Section 250Section 80A(5)Section 80P

There is a delay of 371 days in filing this appeal before the Tribunal. The assessee had filed a petition for condonation of delay supported by an affidavit of the Secretary of the assessee co-operative bank. The reasons stated for belated filing of the appeal, reads as follow ... satisfied that there is sufficient cause for belated filing of this appeal and no latches can be attributed to the assessee. Hence, we condone the delay of 371 days in filing this appeal and proceed to dispose of the same on merits. 3. The grounds raised read as follows

Koyamu Kakkat, Calicut vs. ITO, Kozhikode

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

ITA 228/COCH/2025[2015-16]Status: DisposedITAT Cochin16 May 2025AY 2015-16

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

For Appellant: Shri G. Santhosh Pai, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)

outset we find that there is a delay of 327 days in filing the present appeal. The appellant filed a petition seeking condonation of delay in filing the appeal, wherein it is stated that the appellant is a senior citizen aged 72 years, was bed ridden from February 2024. Therefore ... averments made in the condonation petition, it is evident that the appellant is prevented by reasonable cause from filing the appeal. Therefore, we condone the delay and admit the appeal for adjudication. 6. The learned counsel for the assessee submitted that the AO erred in making addition