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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

Jayant Gramin Bigar Sheti Sahakari Pat Sanstha, Sangli vs. ITO Ward 5 Sangli, Sangli

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

ITA 2873/PUN/2024[2016-17]Status: DisposedITAT Pune04 Apr 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2016-17

For Appellant: Shri Umeshkumar Madhukar MaliFor Respondent: Shri Ramnath P Murkunde
Section 144Section 147Section 147rSection 148Section 3Section 69A

appeal is filed late by 132 days as the impugned order was served on 24.05.2023. The appellant has filed application for condonation of delay in filing of appeal. This application is reproduced below- 15. If reply to 14 is yes, enter the There is delay in submission of appeal grounds ... condonation of delay (not the assessee Cooperative Society Due to exceeding 500 words) technical issues copy of technical problems enclosed requesting to condone the same. 3. In the 'Statement of Facts', the appellant has stated that its consultant created one e-mail id and mentioned

The Mamatha Consumers Cooperative Central Stores Limited, Mancherial vs. Incometax Officer, Ward-1, Mancherial

In the result, the appeal of the assessee in ITA no

ITA 1361/HYD/2024[2016-17]Status: DisposedITAT Hyderabad04 Apr 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri K.A. Sai Prasad, C.AFor Respondent: Dr. Sachin Kumar, Sr-DR
Section 147Section 148

assessee filed appeal before the Ld. CIT(A) with a delay of 105 days. The Ld. CIT(A), without condoning the delay dismissed the appeal of the assessee. 5. Aggrieved with the order of Ld. CIT(A), the assessee is in appeal before us. The Learned Authorised Representative ... their submission, the Ld. AR invited our attention to page no.5 of the order of Ld. CIT(A), where the petition for condonation of delay filed by the assessee has been captured by Ld. CIT(A). The Ld. AR also invited our attention to page nos.8 & 9 of the order

The Mamatha Consumers Cooperative Cnetral Stores Limited, Mancherial vs. Income Tax Officer, Ward-1, Mancherial

In the result, the appeal of the assessee in ITA no

ITA 1360/HYD/2024[2015-16]Status: DisposedITAT Hyderabad04 Apr 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri K.A. Sai Prasad, C.AFor Respondent: Dr. Sachin Kumar, Sr-DR
Section 147Section 148

assessee filed appeal before the Ld. CIT(A) with a delay of 105 days. The Ld. CIT(A), without condoning the delay dismissed the appeal of the assessee. 5. Aggrieved with the order of Ld. CIT(A), the assessee is in appeal before us. The Learned Authorised Representative ... their submission, the Ld. AR invited our attention to page no.5 of the order of Ld. CIT(A), where the petition for condonation of delay filed by the assessee has been captured by Ld. CIT(A). The Ld. AR also invited our attention to page nos.8 & 9 of the order

Ashok Chaurasia, Parbatipur vs. Income Tax Officer, Haldia

Appeal are allowed for statistical purposes

ITA 358/KOL/2024[2014-15]Status: DisposedITAT Kolkata04 Apr 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 250Section 44ASection 68

Registry has informed that the appeal filed by the assessee is barred by limitation of time by 235 days. An application seeking condonation of delay has been filed by the assessee stating as follows for condoning the delay: “With respectfully, I, Ashok Chaurasia being the assessee PAN- AGLPC4543R Trade Name ... have also attached medical report with this letter for your perusal and deep sympathy. Therefore, I would request you to grant the condonation of delay in filing appeal and obliged me.” 1.2. Considering the application for condonation of delay and the reasons stated therein, we are satisfied that the assessee

M/S. Seth B D Goyal Charitable Trust, Kolkata vs. I.T.O. Ward - 1(3), Exemption, Kolkata

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

ITA 2267/KOL/2024[2020-2021]Status: DisposedITAT Kolkata04 Apr 2025AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 11Section 143(1)Section 143(1)(a)Section 250

assessee is in appeal before the Tribunal raising the following grounds of appeal: “1 For that the Ld. CIT(A) erred in not condoning the delay in filing the appeal even when reasonable cause for not filing the appeal within time was duly explained. 2. For that ... account of application of income during the year without assigning any reason. The appeal was delayed and the request for condonation of delay was held to be not liable to be accepted and the appeal was liable to be dismissed on this ground only. The Ld. Addl./Joint

The Suramangalam Co-Op. House Builing Society Ltd., Salem vs. ITO, Ward-1(1), Salem

In the result the assessee’s appeal for ITA No

ITA 2997/CHNY/2024[2019-20]Status: DisposedITAT Chennai04 Apr 2025AY 2019-20

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita 2996 / Chny/2024, Assessment Years-2018-19 आयकर अपील सं./Ita 2997 / Chny/2024, Assessment Years-2019-20

For Appellant: Mr..S.Sridhar, Advocate (Erode) by virtualFor Respondent: Dr.I.Roopa, Addl. CIT
Section 80P

affirmed by the Ld. First Appellate Authority. The Ld. Counsel further submitted that in compliance to latest CBDT instruction empowering CCIT to condone the delay in specified cases, it has petitioned condonation of delay and the same was pending. It was urged that in the event of its application getting ... deduction u/s 80P on account of belated return filed by the assessee. In consideration of latest CBDT instruction, the assessee has petitioned condonation of delay before the competent authority. We therefore in the interest of Page - 2 - of 3 ITA No.2996 & 2997/Chny/2024 justice, set aside the order of lower authorities

The Suramangalam Co-Op. House Building Society Ltd., Salem vs. ITO, Ward-1(1), Salem

In the result the assessee’s appeal for ITA No

ITA 2996/CHNY/2024[2018-19]Status: DisposedITAT Chennai04 Apr 2025AY 2018-19

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita 2996 / Chny/2024, Assessment Years-2018-19 आयकर अपील सं./Ita 2997 / Chny/2024, Assessment Years-2019-20

For Appellant: Mr..S.Sridhar, Advocate (Erode) by virtualFor Respondent: Dr.I.Roopa, Addl. CIT
Section 80P

affirmed by the Ld. First Appellate Authority. The Ld. Counsel further submitted that in compliance to latest CBDT instruction empowering CCIT to condone the delay in specified cases, it has petitioned condonation of delay and the same was pending. It was urged that in the event of its application getting ... deduction u/s 80P on account of belated return filed by the assessee. In consideration of latest CBDT instruction, the assessee has petitioned condonation of delay before the competent authority. We therefore in the interest of Page - 2 - of 3 ITA No.2996 & 2997/Chny/2024 justice, set aside the order of lower authorities

Sri Alagumalai Murugan Trust, Tiruppur vs. ACIT, Exemptions, Coimbatore

ITA 2995/CHNY/2024[2020-21]Status: DisposedITAT Chennai04 Apr 2025AY 2020-21

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita 2994 / Chny/2024, Assessment Years-2019-20 आयकर अपील सं./Ita 2995 / Chny/2024, Assessment Years-2020-21 Sri Alagumalai Murugan Trust, No.9, Selvi Complex, Dharapuram Road, Kandiyan Kovil, Tirupur, Tamil Nadu-641 608. [Pan: Aabta9235E] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख /Date Of Pronouncement : The Assistant Commissioner Of Income Tax, Exemptions, Coimbatore. (प्रत्यर्थी/Respondent) Mr..S.Sridhar, Advocate (Erode) By Virtual : Dr.I.Roopa, Addl. Cit : 27.02.2025 : 04.04.2025 आदेश / Order Per Amitabh Shukla, A.M : The Below Mentioned Appeals Have Been Filed By The Appellant Assessee For Ay-2019-20 & Ay-2020-21 Contesting The Order Of Ld. First Appellate Authority Indicated Column-E, Herein Below:- S. No. A Appeal Nos. B Ays C Appellant D Cit(A) Order Details E Respondent F

Section 10Section 119(2)(b)Section 143(1)

assesee submitted that form 10 was belatedly filed and that, in terms of extant instructions of CBDT it has applied for condonation of delay before the competent authority. It has also been argued that CPC has erroneously added gross receipts as against net receipts. The Ld Council for the assesee ... Rs.67,76,57,091/-. 4. On appeal, the assessee brought to the Ld.CIT(A)'s notice that it had filed application for condoning the delay in belatedly filing Audit Report in Form 10BB before the CBDT through an application filed via mail on 09.03.2024 u/s.119

Sri Alagumalai Murugan Trust, Tirupur vs. ACIT, Exemptions, Coimbatore

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

ITA 2994/CHNY/2024[2019-20]Status: DisposedITAT Chennai04 Apr 2025AY 2019-20

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita 2994 / Chny/2024, Assessment Years-2019-20 आयकर अपील सं./Ita 2995 / Chny/2024, Assessment Years-2020-21

For Appellant: Mr..S.Sridhar, Advocate (Erode) by virtualFor Respondent: Dr.I.Roopa, Addl. CIT
Section 10Section 119(2)(b)Section 143(1)

assesee submitted that form 10 was belatedly filed and that , in terms of extant instructions of CBDT it has applied for condonation of delay before the competent authority. It has also been argued that CPC has erroneously added gross receipts as against net receipts. The Ld Council for the assesee ... Rs.67,76,57,091/-. 4. On appeal, the assessee brought to the Ld.CIT(A)’s notice that it had filed application for condoning the delay in belatedly filing Audit Report in Form 10BB before the CBDT through an application filed via mail on 09.03.2024 u/s.119

S.Latha, Coimbatore vs. ACIT, Coimbatore

In the result, appeal filed by the assessee is dismissed

ITA 1381/CHNY/2017[2012-13]Status: DisposedITAT Chennai04 Apr 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.N.V.Krishnan, AdvocateFor Respondent: Ms.S. Anu Radha, JCIT
Section 143(3)Section 234ASection 249(4)Section 80G

days in filing of this appeal. Since assessee was prevented by sufficient cause, the Ld. Counsel for the assessee prayed for condonation of delay, for which, the Ld.DR didn’t raise any objection and hence, we condone the delay of ‘2’ days and proceed to adjudicate the appeal on merits

Balwas Charitable Trust, Mumbai vs. Income Tax Officer (Exemption)-1(1), Mumbai

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

ITA 897/MUM/2025[2010-11]Status: DisposedITAT Mumbai04 Apr 2025AY 2010-11

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Smt. Renu Jauhribalwas Charitable Trust Vs. Ito(E)-1(1) 265-E, Ballasis Road, Room No. 611, 6Th Mumbai Central, Mumbai – Floor, Cumballa Hill 400008. Mtnl Te Bldg, Pedder Road, Ld.Dr. Gopalrao Deshmukh Marg, Mumbai Pan/Gir No. Aabtb0244Q (Applicant) (Respondent)

Section 250

delay in filing the present appeal. In this regard Ld. AR drawn our attention towards affidavit filed by the assessee, thereby seeking condonation of delay and the contents of which were reproduced here in below: 7. The appellant state that only after receiving "Recovery Notice for Outstanding Demand" from ... property explained the delay which occurred in filing the appeal the expression ‘sufficient cause’ is being liberally construed, therefore we are inclined to condone the delay in filing the present and order. Accordingly, now the appeal is admitted to be heard on merits. 6. After hearing the parties

Krishnakant Sharma (Lh of Late Vimaladevi Sharma), Mumabi vs. Income Tax Officer - 23(3)(5), Mumbai

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

ITA 418/MUM/2025[2012-2013]Status: DisposedITAT Mumbai04 Apr 2025AY 2012-2013

Bench: Shri Br Baskaran & Shri Sandeep Gosain

Section 147Section 250

filing the present appeals and in this regard an affidavit has been filed by the assessee Therefore, after hearing the parties on condonation of delay and after going through the contents of the affidavit and keeping in view, the principles laid down by Hon’ble Supreme Court in the case ... property explained the delay which occurred in filing the appeal, the expression ‘sufficient cause’ is being liberally construed, therefore we are inclined to condone the delay in filing the appeal and heard on merits. 3. Now, as far as the merits of the case is concerned. It is noticed that

Krishnakant Sharma (Lh of Late Vimaladevi Sharma), Mumbai vs. Income Tax Officer - 23(3)(5), Mumbai

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

ITA 417/MUM/2025[2011-2012]Status: DisposedITAT Mumbai04 Apr 2025AY 2011-2012

Bench: Shri Br Baskaran & Shri Sandeep Gosain

Section 147Section 250

filing the present appeals and in this regard an affidavit has been filed by the assessee Therefore, after hearing the parties on condonation of delay and after going through the contents of the affidavit and keeping in view, the principles laid down by Hon’ble Supreme Court in the case ... property explained the delay which occurred in filing the appeal, the expression ‘sufficient cause’ is being liberally construed, therefore we are inclined to condone the delay in filing the appeal and heard on merits. 3. Now, as far as the merits of the case is concerned. It is noticed that

Silver Cascade Cooperative Hsg. Soc. Ltd, Mumbai vs. DCIT Circle 23, Mumbai

In the result appeal filed for assessment years 2018-19 and 2020-21 stands partly allowed for statistical purposes

ITA 146/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Apr 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 142(1)

time on 27/12/2021 resulting in a technical delay of 256 days [286 days (16/03/2021 το 27/12/2021)-30days). e. The society requested for condonation of delay in Appeal Filed before CIT(A) in Form 35 before the CIT (A). f. The society had submitted the bank statements, certificate, society registration ... I.T.A. No.145 & 146/Mum/2025 AY:2018-19 & 2020-21 Silver Cascade Co-operative Hsg. Soc. Ltd n. The society had made appeal for Condonation of Delay on the above facts and circumstances in Form 35 before the CIT (A). o. The Form 35 for AY 2020-21 was filed wherein

Silver Cascade Cooperative Hgs. Soc.Ltd, Mumbai vs. DCIT, Circle 2(3)(1), Mumbai

In the result appeal filed for assessment years 2018-19 and 2020-21 stands partly allowed for statistical purposes

ITA 145/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Apr 2025AY 2018-19

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 142(1)

time on 27/12/2021 resulting in a technical delay of 256 days [286 days (16/03/2021 το 27/12/2021)-30days). e. The society requested for condonation of delay in Appeal Filed before CIT(A) in Form 35 before the CIT (A). f. The society had submitted the bank statements, certificate, society registration ... I.T.A. No.145 & 146/Mum/2025 AY:2018-19 & 2020-21 Silver Cascade Co-operative Hsg. Soc. Ltd n. The society had made appeal for Condonation of Delay on the above facts and circumstances in Form 35 before the CIT (A). o. The Form 35 for AY 2020-21 was filed wherein

Abdul Sattar Nagori, Mumbai vs. Income Tax Officer 31(1)(1) Mumbai, Mumbai

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

ITA 3590/MUM/2024[2017-18]Status: DisposedITAT Mumbai04 Apr 2025AY 2017-18

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanabdul Sattar Nagori Ito 31(1)(1), Shop No. 123, Citi Centre S. V. Road, Kautilya Bhavan Bandra Kurla Goregaon West, Mumbai-400 062 Vs. Complex Bandra East, Pan: Ainpb2060N Mumbai-400 051

Section 142(1)Section 144Section 234ASection 250

brought to our notice the affidavit filed by the assessee which are reproduced below:- That this affidavit is being filed for the condonation of delay in filing the appeal against the order of the Commissioner of uncome Tax (Appeals)-3, Coimbatore, by the National Faceless Appeal, al Centre, Centre, Delhi ... diligently and with utmost sincerity. That I humbly pray that in the interest of justice, this Hon'ble Tribunal may be pleased to condone the delay in filing the appeal and consider the same on merits. That the facts stated above are true to the best of my knowledge

Sharda Rani Gupta L/H Late Hem Chand Gupta, New Delhi vs. ITO, Ward 55(4), New Delhi

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

ITA 2055/DEL/2023[2009-10]Status: DisposedITAT Delhi04 Apr 2025AY 2009-10

Bench: Shri Vikas Awasthyआअसं.2055/िद"ी/2023 (िन.व. 2009-10) Mrs Sharda Rani Gupta, L/H Late Hem Chand Gupta C/O Mr. Sandeep Bhatnagar, C.A, Flat No. 12, 2Nd Floor, Sheel Tara House, 4866/24, Ansari Road, Darya Ganj, New Delhi 110002 ...... अपीलाथ"/Appellant Pan: Aakpg-2688-Q बनाम Vs. Income Tax Officer, Ward 55(4), ..... "ितवादी/Respondent D-Block, Vikas Bhawan, New Delhi 110002 अपीलाथ" "ारा/ Appellant By : None "ितवादी"ारा/Respondent By : Ms. Shivani Bansal, Sr. Dr & Shri Om Prakash, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 10/01/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 04/04/2025 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 18.04.2023, For Assessment Year 2009-10. 2. The Appeal Is Time Barred By 29 Days. The Assessee Has Filed An Application Seeking Condonation Of Delay In Filing Of Appeal. After Perusal Of The Same, I Am Satisfied That Delay In Filing Of Appeal Is Not Intentional, But Was For The Reasons

For Appellant: NoneFor Respondent: Ms. Shivani Bansal, Sr. DR and Shri Om Prakash, Sr. DR
Section 133(6)Section 254Section 68

dated 18.04.2023, for assessment year 2009-10. 2. The appeal is time barred by 29 days. The assessee has filed an application seeking condonation of delay in filing of appeal. After perusal of the same, I am satisfied that delay in filing of appeal is not intentional

Sudhir Yadav, Agra vs. Income Tax Officer, Ward-1(1)(5), Agra

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

ITA 82/AGR/2025[2012-13]Status: DisposedITAT Agra03 Apr 2025AY 2012-13

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13]

Section 147

doors against him. The length of delay is immaterial. It is the acceptability of the explanation that is the only criteria for condoning the delay. 5. In the case of Collector, Land Acquisition vs. Mst Katiji & Ors (1987) 167 ITR 471 (S.C) (S.C) the Hon'ble Supreme Court ... trend setting pronouncement held as under:- "Appeal (Tribunal)-Condonation of delay "Sufficient cause" "Sufficient cause" for the purpose of condonation of delay should be interpreted with a view to do even handed justice on merits in preference to approach which scuttles a decision on merits-The power to condone delay

Rajveer Singh, Mehrauni vs. ITO, Lalitpur

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

ITA 77/AGR/2025[2012-13]Status: DisposedITAT Agra03 Apr 2025AY 2012-13

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13]

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 50C

dismissed the appeal of the assessee in limine under the provisions of 249(3) r.w.s. 250 of the Act by not condoning the delay of 42 days in filing of the appeal before the Ld. CIT(A). 5. Aggrieved with the said order, the assessee is in appeal before ... have heard the ld. DR and perused the material available on record. The assessee had made an application for condonation of delay on 14.02.2020 before the ld. CIT(A), which is reproduced as under:- "The appellant is a illiterate daily wages worker who use to work with different contractors

Dinesh Kumar, Agra vs. Income-Tax Officer, Ward-2(1)(1), Agra

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

ITA 65/AGR/2025[2012-2013]Status: DisposedITAT Agra03 Apr 2025AY 2012-2013

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2012-13]

Section 142(1)Section 144Section 156

delay of one year. In this regard, the assessee has filed a condonation application dated 01.02.2025 which is reproduced as under:- “Sub: Condonation of delay the learned Commissioner of Income-tax (Appeals), NFAC, Delhi dated 08.02.2024. The said appeal was to be filed by 08.04.2024 but could not be filed ... Appellant opted for the Vivad Se Vishwas (VSV) Scheme that he became aware of the appellate order passed Therefore, we request you to condone the delay in filing of appeal in light of the principal of natural justice and acknowledge the receipt of the same.” 2.1. The explanation