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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

Girjan Co-Op Marketing Society Limited, Vizianagaram vs. Income Tax Officer, Ward-1, Vizianagaram

In the result, four appeals filed by the assessee are allowed for statistical purposes as indicated hereinabove

ITA 274/VIZ/2024[2016-17S]Status: DisposedITAT Visakhapatnam09 Dec 2024

Bench: Shri K.Narasimha Chary & Shri S. Balakrishnan

For Appellant: Shri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 10Section 139Section 142(1)Section 144Section 144BSection 147Section 148Section 154Section 271(1)(c)

prevented by a reasonable and sufficient cause in filing the present appeals before the Tribunal beyond the prescribed time limit. Hence, we hereby condone the delay of 24 days in filing the appeals and proceed to adjudicate the appeals on merits. 4. Brief facts of the case are that ... learned CIT(A), the assessee made submissions explaining the reasons for not filing the appeals within the prescribed time limit and sought for condonation of delay. In condonation of delay petition, the assessee submitted that since the assessee-society is a Primary Cooperative Marketing Society, operating for welfare

Girjan Co-Op Marketing Society Limited, Vizianagaram vs. Income Tax Officer, Ward-1, Vizianagaram

In the result, four appeals filed by the assessee are allowed for statistical purposes as indicated hereinabove

ITA 273/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam09 Dec 2024AY 2016-17

Bench: Shri K.Narasimha Chary & Shri S. Balakrishnan

For Appellant: Shri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 10Section 139Section 142(1)Section 144Section 144BSection 147Section 148Section 154Section 271(1)(c)

prevented by a reasonable and sufficient cause in filing the present appeals before the Tribunal beyond the prescribed time limit. Hence, we hereby condone the delay of 24 days in filing the appeals and proceed to adjudicate the appeals on merits. 4. Brief facts of the case are that ... learned CIT(A), the assessee made submissions explaining the reasons for not filing the appeals within the prescribed time limit and sought for condonation of delay. In condonation of delay petition, the assessee submitted that since the assessee-society is a Primary Cooperative Marketing Society, operating for welfare

Girijan Co-Op Marketing Society Limited, Vizianagaram vs. Income Tax Officer, Ward-1, Vizianagaram

In the result, four appeals filed by the assessee are allowed for statistical purposes as indicated hereinabove

ITA 272/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam09 Dec 2024AY 2016-17

Bench: Shri K.Narasimha Chary & Shri S. Balakrishnan

For Appellant: Shri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 10Section 139Section 142(1)Section 144Section 144BSection 147Section 148Section 154Section 271(1)(c)

prevented by a reasonable and sufficient cause in filing the present appeals before the Tribunal beyond the prescribed time limit. Hence, we hereby condone the delay of 24 days in filing the appeals and proceed to adjudicate the appeals on merits. 4. Brief facts of the case are that ... learned CIT(A), the assessee made submissions explaining the reasons for not filing the appeals within the prescribed time limit and sought for condonation of delay. In condonation of delay petition, the assessee submitted that since the assessee-society is a Primary Cooperative Marketing Society, operating for welfare

Girijan Co-Op Markrting Society Limited, Vizianagaram vs. Income Tax Officer, Ward-1, Vizianagaram

In the result, four appeals filed by the assessee are allowed for statistical purposes as indicated hereinabove

ITA 271/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam09 Dec 2024AY 2016-17

Bench: Shri K.Narasimha Chary & Shri S. Balakrishnan

For Appellant: Shri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 10Section 139Section 142(1)Section 144Section 144BSection 147Section 148Section 154Section 271(1)(c)

prevented by a reasonable and sufficient cause in filing the present appeals before the Tribunal beyond the prescribed time limit. Hence, we hereby condone the delay of 24 days in filing the appeals and proceed to adjudicate the appeals on merits. 4. Brief facts of the case are that ... learned CIT(A), the assessee made submissions explaining the reasons for not filing the appeals within the prescribed time limit and sought for condonation of delay. In condonation of delay petition, the assessee submitted that since the assessee-society is a Primary Cooperative Marketing Society, operating for welfare

Shyamal Kumar Ghosh, Kolkata vs. I.T.O., Ward - 33(5), Kolkata

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

ITA 1813/KOL/2024[2017-2018]Status: DisposedITAT Kolkata09 Dec 2024AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.1813/Kol/2024 Assessment Year: 2017-18 Shyamal Kumar Ghosh……………………………………………….…..……Appellant 40, Weston Street, 2Nd Floor, Bowbazar, Kolkata – 700013. [Pan: Adtpg3720F] Vs. Ito, Ward-33(5), Kolkata............…..….…..….........……........……...…..…..Respondent Appearances By: Shri Abhishek Bansal, Ar, Appeared On Behalf Of The Appellant. Shri Akhil Kumar, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 12, 2024 Date Of Pronouncing The Order : December 09, 2024 Order Per Sonjoy Sarma: The Present Appeal Is Filed By The Assessee Against The Order Dated 12.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Ld. Ar Raised Issue Of A Delay Of 198 Days In Filing The Instant Appeal. The Assessee Has Submitted An Application For Condonation Of Delay Citing Valid & Proper Reasons. After Considering The Averments Made In The Application, We Condone The Delay. 3. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Assessment Year 2017-18 By Declaring Gross Total Income Of Rs.14,15,352/- & Total Income Of Rs.12,49,520/- After Deduction Under Chapter Vi-A Of The Act. The Case Of The Assessee Was Selected For Scrutiny & Notices U/S 143(2) & 142(1) Of The Act Were Issued. In Response, The Assessee Submitted Profit & Loss A/C, Balance Sheet And

Section 133(6)Section 143(2)Section 145(3)Section 250Section 44ASection 68Section 69A

raised issue of a delay of 198 days in filing the instant appeal. The assessee has submitted an application for condonation of delay citing valid and proper reasons. After considering the averments made in the application, we condone the delay. 3. Brief facts of the case are that the assessee

The Pavaratty Service Co Operative Bank Ltd No 3918, Pavaratty vs. Income Tax Officer, Ward 1& Tps, Guruvayur

In the result, the appeal as well as the stay application filed by the assessee are dismissed

ITA 583/COCH/2024[2023-2024]Status: DisposedITAT Cochin09 Dec 2024AY 2023-2024

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Ramdas, CAFor Respondent: Smt.Leena Lal, Senior AR
Section 119(2)(b)Section 80P

assessee has filed an application u/s.119(2)(b) before the CBDT praying for 2 ITA No.583 & SA 180/Coch/2024. The Pavaratty SCB Limited condonation of delay in filing the return of income. The same is pending with the CBDT till date. However, the learned jurisdictional AO without appreciating the outcome ... that the same is pending before the CBDT till date. Therefore, having regard to the fact that the ITAT has no power to condone the delay for accepting belated return, which power squarely is in the domain of the CBDT, and hence, it cannot be possible to condone the delay

Crescent Service Society, Alappuzha vs. Dy.Director of Incometax CPC, Bengaluru

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

ITA 340/COCH/2024[2022-23]Status: DisposedITAT Cochin09 Dec 2024AY 2022-23

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Shafeeq A.M., CAFor Respondent: Smt.Leena Lal, Senior AR
Section 12A

granted if any statutory compliance could not be made in accordance with law. The assessee is at liberty to file a petition for condonation of delay in filing the Form No.10 before the CIT who has been given powers to condone the delay in filing of Form

Chittattukara Panchayat Service Co-Op Bank Ltd, Ernakulam vs. The ITO Ward 1 & Tps, Aluva

In the result, the appeal filed by the assessee is allowed for statistical purposes and the stay application is dismissed

ITA 629/COCH/2023[2017-18]Status: DisposedITAT Cochin09 Dec 2024AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: --- None ---For Respondent: Smt.Leena Lal, Senior AR
Section 143(3)Section 80P

present appeal by 24 days. The assessee filed a petition along 2 ITA No.629/Coch/2023. Chittattukara Panchayat SCB Limited. with an affidavit praying for condonation of delay on the ground that the order passed by the CIT(A) was not served physically but through e-mail which was not noticed ... interest of justice adopting a liberal view. 3. On the other hand, the learned CIT-DR has not seriously opposed the condonation of delay. 4. There is no material on record to disbelieve the averments made in the affidavit explaining the reasons for the delay in filing the present appeal

M/S. Pachiyamman Ethirajammal Rajam Mudaliyandan Educational Trust, Chennai vs. ITO, Exemption Ward-1, Chennai

In the result, the appeal filed by the assesse in ITA No

ITA 1981/CHNY/2024[2017-18]Status: DisposedITAT Chennai09 Dec 2024AY 2017-18

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.1981/Chny/2024 (िनधा"रणवष" / Assessment Year: 2017-2018) M/S. Pachiyamman Ethirajammal Rajam Vs. The Income Tax Officer, Mudaliyandan Educational Trust, Exemptions Ward -1, No.66, Sriram, 1St Cross Street, Chennai. Venus Colony, Alwarpet, Chennai 600 018. [Pan: Aaatp 3474H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Ms. S. Jecintha, Advocate ""यथ" क" ओर से /Respondent By : Ms.R. Anita, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 04.12.2024 घोषणा क" तार"ख /Date Of Pronouncement : 09.12.2024 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Ms. S. Jecintha, AdvocateFor Respondent: Ms.R. Anita, IRS, Addl. CIT
Section 10Section 129Section 12ASection 142(1)Section 143(2)Section 143(3)

allow the exemption claimed under Section 10(23C) (vi) of the Act. The assessee filed Form 10BB on 04.12.2019 and requested for condonation for delay before the Commissioner of Income-tax, Exemptions, Chennai which is pending for condonation for the assessment year 2017-18. The ld. Assessing Officer after scrutinizing ... Officer on the ground that assessee has not filed required form 10BB of the Act on time. and the CIT(E) has not condoned the delay for accepting the form 10BB of the Act. Aggrieved by the order of the ld. CIT(A), the assessee filed an appeal before

Mentor Foundation, Jaipur vs. CIT(Exemption), Jaipur

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

ITA 787/JPR/2024[2023-24]Status: DisposedITAT Jaipur09 Dec 2024AY 2023-24

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

For Appellant: Shri K.L. Moolchandani, ARFor Respondent: Shri Arvind Kumar, CIT-DR
Section 12ASection 2(15)

appeal by the assessee for which the assessee vide application dated 21-08-2023 filed a condonation application with the prayer to condone the delay of one day in filing the appeal. To this effect, 3 ITA787/JPR/2024 MENTOR FOUNDATION VS CIT (E), JAIPUR the assessee has filed an affidavit with ... assessee and found that this is not an inordinate delay and the assessee has reasonable cause to consider his application for condonation of delay of one day and there is merit in his submission. Hence, the delay of one day in filing the appeal by the assessee is condoned

Star Developers, Jaipur vs. ITO Ward - 1(4), Jaipur

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

ITA 1138/JPR/2024[2022-23]Status: DisposedITAT Jaipur09 Dec 2024AY 2022-23

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

For Appellant: Shri R.S. Poonia, CAFor Respondent: Shri Gautam Singh Choudhary Addl.CIT
Section 143(1)Section 249(3)Section 250

that there is delay of 11 days in filing the appeal by the assessee for which the assessee has filed an application for condonation of delay with following prayer. ‘’1. That assessee-firm filed an appeal on 03-09-2024 against the ex-parte order passed by ld. Addl./JCIT ... filing of appeal before ITAT, Jaipur In view of above submissions, you are requested that kindly consider this as reasonable cause to condone the delay of 11 days so that proper inquiry can be conducted and substantial justice may be delivered to the appellant 2.2 To this effect, the assesee

Dinesh Ratilal Ajmera, Mumbai vs. Income Tax Officer Ward 20(1)(1), Mumbai

In the result, the appeal is allowed

ITA 5529/MUM/2024[2017-18]Status: DisposedITAT Mumbai09 Dec 2024AY 2017-18

Dinesh Ratilal Ajmera. 6. The principles which are germane while considering a prayer for condonation of delay are now well settled. The extent of the delay is not strictly material. What has to be seen is whether the appellant has made out “sufficient cause” for not filing the appeal within ... after taking note of several decisions holding the field, has culled out the principles which are relevant in the matter of condonation of delay. It has been inter alia held that there is no presumption that the delay is intentional, as no party stands to gain by approaching the court

Deputy Commissioner of Income Tax, Mumbai, Aayakar Bhavan vs. Firefly Market Research India Private Limited, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 4184/MUM/2024[2015-16]Status: DisposedITAT Mumbai09 Dec 2024AY 2015-16

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailassessment Year 2015-16

For Appellant: Shri Ajit JainFor Respondent: Ms. Rajeshwari Menon, Sr. DR
Section 143(3)Section 250Section 40Section 40A(2)(b)Section 40a

Appeal Centre, Delhi [“learned CIT(A)”] for the assessment year 2015-16. 2 2. Having considered the submissions made in the application seeking condonation of delay, the delay of 25 days in filing the present appeal is condoned. 3. In this appeal, the Revenue has raised the following grounds

Amar Harshad Dani, Mumbai vs. ITO, Ward, 3(1), Mumbai

ITA 4099/MUM/2024[2013-14]Status: DisposedITAT Mumbai09 Dec 2024AY 2013-14

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Siddharth SrivastavaFor Respondent: Shri Ram Krishn Kedia
Section 144Section 147Section 148Section 250

NFAC, Delhi has erred in the dismissing the appeal of the Appellant on account of rejection of the petition for condonation of delay despite the fact the at the appeal was Assessment Year 2013-2014 already admitted by the Ld. CIT(A), NFAC, Delhi by issuing notice of hearing under ... NFAC, Delhi has erred in retrospectively dismissing the appeal of the Appellant on account of rejection of the petition for condonation of delay without giving any opportunity o being heard to the Appellant.” 3. The relevant facts are in brief are that the assessment was completed vide the Assessment Order

Sanket Subhash Hande, Mumbai vs. Assistant Commissioner of Income Tax, Circle 1, Thane

In the result, in view of the decision of ITA No

ITA 1258/MUM/2024[2020-21]Status: DisposedITAT Mumbai09 Dec 2024AY 2020-21

Bench: Shri Narender Kumar Choudhryassessment Year: 2020-21 & Assessment Year: 2020-21

For Appellant: Shri Bharat Kumar, Ld. A.RFor Respondent: Shri V.K. Chaturvedi, Ld. Sr. D.R
Section 143(1)Section 250

settlement under VSVS 2024, the delay may be condoned. On the contrary, the Ld. D.R. refuted the claim of the Assessee qua condonation of delay. 6. This Court has given thoughtful considerations to the peculiar facts and circumstances of the case and the reason for delay in filing the appeal ... prima-facie seems to be bonafide, genuine and sufficient but not supported by any document or affidavit and therefore considering the reason for condonation of delay and peculiar fact that the Assessee has bonafide intention to settle the dispute and in pursuance to his intention, has opted for VSVS

Sanket Subhash Hande, Mumbai vs. Assistant Commissioner of Income Tax, Circle, Thane., Mumbai

In the result, in view of the decision of ITA No

ITA 1257/MUM/2024[2020-21]Status: DisposedITAT Mumbai09 Dec 2024AY 2020-21

Bench: Shri Narender Kumar Choudhryassessment Year: 2020-21 & Assessment Year: 2020-21

For Appellant: Shri Bharat Kumar, Ld. A.RFor Respondent: Shri V.K. Chaturvedi, Ld. Sr. D.R
Section 143(1)Section 250

settlement under VSVS 2024, the delay may be condoned. On the contrary, the Ld. D.R. refuted the claim of the Assessee qua condonation of delay. 6. This Court has given thoughtful considerations to the peculiar facts and circumstances of the case and the reason for delay in filing the appeal ... prima-facie seems to be bonafide, genuine and sufficient but not supported by any document or affidavit and therefore considering the reason for condonation of delay and peculiar fact that the Assessee has bonafide intention to settle the dispute and in pursuance to his intention, has opted for VSVS

Shree Swami Samarth Bhakt Seva Sangh, Pune vs. CIT Exemption, Pune

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

ITA 1413/PUN/2024[2024-25]Status: DisposedITAT Pune06 Dec 2024AY 2024-25

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1413/Pun/2024 Shree Swami Samarth Bhakt Vs. Cit(Exemption) Seva Sangh, Pune Peth No.26, Samarth Nagar, Pradhikaran Nigadi, Pune 411 044, Maharashtra Pan : Aacts9069D Appellant Respondent

For Appellant: Shri Siddharth OswalFor Respondent: Shri Ajay Kumar Keshari
Section 12(1)(ac)Section 12A

Court in the case of Vijay Vishin Meghani vs. DCIT, 389 ITR 250 (Bom.) wherein it was held that in the matter of condonation of delay an overall view in the larger interest of justice has to be taken. None should be deprived of an adjudication on merits unless ... deliberately and intentionally delayed filing of the appeal, that he is careless, negligent and his conduct is lacking in bonafides. We therefore condone the delay of 26 days in filing the appeal and proceed for adjudication of appeal. 3. Briefly stated, the facts of the case are that the appellant

Aditi Express Cargo India Private Limited, Nagpur vs. DCIT ACIT Circle -3, Nagpur

In the result, all the captioned seven appeal are allowed for statistical purposes

ITA 560/NAG/2024[2014-15]Status: DisposedITAT Nagpur06 Dec 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: S/Shri Nitin Gulati a/w Pankaj KapoorFor Respondent: Shri Abhay Y. Marathe
Section 142(1)Section 147Section 148Section 250

already been paid in excess. 8. Procedural Lapses in Appeal Proceedings: The Learned Commissioner of Appeals failed to give proper consideration to the condonation of delay and the reasons for the late filing of the appeal. No opportunity was provided to explain the delay adequately. The appellant reserves the right ... deliberate nor intentional but was the result of bona fide and unavoidable circumstances. 8. That I humbly request the Hon'ble Tribunal to condone the delay in filing the appeals and to hear the matters on their merits in the interest of justice. 8. That I humbly request

Aditi Express Cargo India Private Limited, Nagpur vs. DCIT ACIT Circle -3, Nagpur

In the result, all the captioned seven appeal are allowed for statistical purposes

ITA 559/NAG/2024[2014-15]Status: DisposedITAT Nagpur06 Dec 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: S/Shri Nitin Gulati a/w Pankaj KapoorFor Respondent: Shri Abhay Y. Marathe
Section 142(1)Section 147Section 148Section 250

already been paid in excess. 8. Procedural Lapses in Appeal Proceedings: The Learned Commissioner of Appeals failed to give proper consideration to the condonation of delay and the reasons for the late filing of the appeal. No opportunity was provided to explain the delay adequately. The appellant reserves the right ... deliberate nor intentional but was the result of bona fide and unavoidable circumstances. 8. That I humbly request the Hon'ble Tribunal to condone the delay in filing the appeals and to hear the matters on their merits in the interest of justice. 8. That I humbly request

Aditi Express Cargo India Private Limited, Nagpur vs. DCIT ACIT Circle -3, Nagpur

In the result, all the captioned seven appeal are allowed for statistical purposes

ITA 558/NAG/2024[2014-15]Status: DisposedITAT Nagpur06 Dec 2024AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: S/Shri Nitin Gulati a/w Pankaj KapoorFor Respondent: Shri Abhay Y. Marathe
Section 142(1)Section 147Section 148Section 250

already been paid in excess. 8. Procedural Lapses in Appeal Proceedings: The Learned Commissioner of Appeals failed to give proper consideration to the condonation of delay and the reasons for the late filing of the appeal. No opportunity was provided to explain the delay adequately. The appellant reserves the right ... deliberate nor intentional but was the result of bona fide and unavoidable circumstances. 8. That I humbly request the Hon'ble Tribunal to condone the delay in filing the appeals and to hear the matters on their merits in the interest of justice. 8. That I humbly request