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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

Shri Narayana Gurudeva Trust, Nashik vs. Commissioner of Income Tax (E), Pune

ITA 1521/PUN/2024[2024-25]Status: DisposedITAT Pune17 Oct 2024AY 2024-25

Bench: Hon’Ble Smt Astha Chandra & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.1520 & 1521/Pun/2024 Shri Narayan Gurudeva Trust Pakhal Road, Vadala, Nashik-422001 .......अपीलार्थी / Appellant Pan: Aafts0349M

For Appellant: Mr Sanket Joshi [‘Ld. AR’]For Respondent: Mr Ajaykumar Kesari [‘Ld. DR’]
Section 12ASection 12A(1)(ac)Section 2(15)Section 253Section 80G(5)

CBDT Circular 08/2022 dt. 30/09/2022. Thus said application of the appellant was barred by limitation and in absence of statutory provision empowering condonation of delay the application deserved rejection in the light of decision of Hon’ble Madras High Court in ‘All Angels Educational Society Vs CCIT’ [2016, WP/4969/2014 ... appellant was not entitled to the extended time period in terms of circular 08/2023 dt. 24/05/2023, (iii) in absence of explicit provision/power to condone the delay in filing application for regular/final registration and finally (iv) in the absence of regular registration certificate 12AB of the Act. 11. There

Shri Narayana Gurudeva Trust, Nashik vs. Commissioner of Income Tax (Exemption), Pune

ITA 1520/PUN/2024[2024-25]Status: DisposedITAT Pune17 Oct 2024AY 2024-25

Bench: Hon’Ble Smt Astha Chandra & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.1520 & 1521/Pun/2024 Shri Narayan Gurudeva Trust Pakhal Road, Vadala, Nashik-422001 .......अपीलार्थी / Appellant Pan: Aafts0349M

For Appellant: Mr Sanket Joshi [‘Ld. AR’]For Respondent: Mr Ajaykumar Kesari [‘Ld. DR’]
Section 12ASection 12A(1)(ac)Section 2(15)Section 253Section 80G(5)

CBDT Circular 08/2022 dt. 30/09/2022. Thus said application of the appellant was barred by limitation and in absence of statutory provision empowering condonation of delay the application deserved rejection in the light of decision of Hon’ble Madras High Court in ‘All Angels Educational Society Vs CCIT’ [2016, WP/4969/2014 ... appellant was not entitled to the extended time period in terms of circular 08/2023 dt. 24/05/2023, (iii) in absence of explicit provision/power to condone the delay in filing application for regular/final registration and finally (iv) in the absence of regular registration certificate 12AB of the Act. 11. There

Intime Services, Srikakulam vs. Income Tax Officer, National E-Assessment Center, Delhi

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

ITA 50/VIZ/2024[2018-19]Status: DisposedITAT Visakhapatnam17 Oct 2024AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.50/Viz/2024 (िनधा"रण वष" / Assessment Year: 2018-19) Intime Services, Vs. Income Tax Officer, Srikakulam. National E-Assessment Pan: Aadfi0839A Centre, Delhi. (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri C. Subrahmanyam, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 09/10/2024 घोषणा क" तारीख/Date Of : 17/10/2024 Pronouncement O R D E R

For Appellant: Sri C. Subrahmanyam, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 143(2)Section 143(3)Section 249(2)Section 36(1)(v)Section 37Section 43B

there was a delay of 183 in e-filing the appeal before the Ld. CIT(A)-NFAC and assessee has also requested to condone the delay by stating that because of Covid Pandemic assessee could not file the appeal within the stipulated time 4 prescribed under the Act. However ... NFAC rejected the assessee’s plea for condonation of delay and held that appeal of the assessee is not maintainable in view of the provisions of section 249(2) of the Act. Aggrieved by the order of the Ld. CIT(A)- NFAC, the assessee is in appeal before the Tribunal

The Pulimeru Large Size Co-Op Credit Society Limited, Peddapuram vs. Income Tax Officer, Ward-1, Kakinada

ITA 355/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam17 Oct 2024AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.355/Viz/2024 (िनधा"रण वष" / Assessment Year : 2015-16) The Pulimeru Large Size Co-Op Vs. Income Tax Officer, Credit Society Limited, Ward-1, Peddapuram. Kakinada. Pan: Aacat2023M (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri Kss Sarma, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 14/10/2024 घोषणा क" तारीख/Date Of : 17/10/2024 Pronouncement O R D E R

For Appellant: Sri KSS Sarma, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133(6)Section 142(1)Section 147Section 148Section 69A

days in filing the appeal before the First Appellate Authority. Before the Ld. CIT(A)-NFAC, the assessee has filed a petition for condonation of delay and explained the reasons that prevented the assessee in filing the appeal beyond the prescribed time limit. The assessee also pleaded before ... following the grounds of appeal: “1. The order of AO, NFAC is arbitrary and unjust. 2. The Ld. CIT (A) ought to have condone the delay of 72 days as all the members of the society are uneducated and farmers. 3. The Ld. CIT(A) failed to see that

Kalapala Venkat S/O. Kvns Prasad, Krishna District vs. Income Tax Officer, Ward-1, Gudiwada

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

ITA 187/VIZ/2023[2015-16]Status: DisposedITAT Visakhapatnam17 Oct 2024AY 2015-16

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No. 187/Viz/2023 (िनधा"रण वष" / Assessment Year : 2015-16) Kalapala Venkat, Vs. Income Tax Officer, S/O. Kvns Prasad, Ward-1, 5-107, Veeravalli, Gudiwada. Bapulapadu (M), Krishna District, Andhra Pradesh-521130. Pan: Cqhpk 7511 B (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri C. Subrahmanyam, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 08/10/2024 घोषणा क" तारीख/Date Of : 17/10/2024 Pronouncement O R D E R

For Appellant: Shri C. Subrahmanyam, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 144Section 147Section 148Section 69A

days in filing the appeal before the Tribunal. With respect to belated filing of the appeal, the assessee filed a petition for condonation of delay along with the affidavit and the relevant paras of the affidavit are extracted herein below for reference: “……. 2. Whereas, assessee has to go to Counsel ... reasonable and sufficient cause ie., ill health of the assessee to file the appeal beyond the stipulated time. Therefore, I hereby condone the delay of 157 days in filing the appeal of the assessee before the Tribunal and proceed to adjudicate the appeal on merits. 3 4. Briefly stated

Jadwet Associates, Port Blair vs. ACIT, Circle - 3(2), Port Blair

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

ITA 962/KOL/2024[2017-2018]Status: DisposedITAT Kolkata17 Oct 2024AY 2017-2018

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 250Section 253(3)Section 253(5)

October 17th, 2024 ORDER Per Sanjay Awasthi, Accountant Member: In this case there is a delay of 60 days. The appellant has filed condonation of delay petition, along with medical certificate in support of claim that the delay was on genuine grounds and deserves to be condoned. Some portions from

Prathap Seetharama Reddy, Bangalore vs. Assistant Commissioner of Income Tax, Circle-6(3)(1), Bangalaore

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

ITA 1691/BANG/2024[2017-18]Status: DisposedITAT Bangalore17 Oct 2024AY 2017-18
For Appellant: Sri H. Guruswamy, A.RFor Respondent: Sri V. Parithivel, D.R
Section 250

days in filing the appeal before this Tribunal. The assessee has explained the delay before us by filing an application for condonation of delay as follows: BEFORE THE HONOURABLE INCOME TAX APPELLATE TRIBUNAL, BANGALORE BENCH, BANGALORE Prathap Seetharama Reddy Vs. Petitioner/Appellant 1. ACIT, Circle - 6(3)(1) Bangalore ... NFAC, Delhi Respondents APPLICATION FOR CONDONATION OF DELAY 1. The Petitioner begs to submit that an Appeal was filed on 03-09-2024 before the Honourable ITAT, Bangalore against the ex-parte Appellate order dtd: 27-07-2023 passed by the CIT(A), NFAC, Delhi and the appeal filed

Netra Subhash Koregaonkar, Thane (West) vs. Income Tax Officer, Ward 1(5), Thane

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

ITA 4392/MUM/2024[2012-13]Status: DisposedITAT Mumbai17 Oct 2024AY 2012-13

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalnetra Subhash Ito-Ward 1(5), Korgaonkar, Ashar It Park, Wagle बनाम/ 27/A/14 Shyam Kutir Industrial Estate, Vs. Housing Society, Thane (W)-400604, Vrindavan Society, Maharashtra. Thane (W)-400601. Maharashtra. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Bvkpk0520K (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Shri Rajesh Athavale.ARFor Respondent: Shri.Asif Karmali. Sr. DR
Section 144

submitted that there is a delay in filing the appeal before the Hon’ble Tribunal and the assessee has filed an affidavit for condonation of delay. Whereas, the facts mentioned in the affidavit are reasonable 2 ITA.No.4392/Mum/2024. Netra Subhash Koregaonkar., Mumbai and the Ld.DR has no specific objections. Accordingly ... condone the delay and admit the appeal. The assesse has raised the following grounds of appeal: 1. The learned CIT(A) erred in passing the ex-parte order. 2. The learned CIT(A) erred in confirming the addition of INR 6,75,000 as explained income. The learned

H K & Co, Mumbai vs. Income Tax Officer- Ward- 17(1)(5), Mumbai

In the result, the appeal filed by the Assessee stands allowed for statistical purposes

ITA 2985/MUM/2024[2015-16]Status: DisposedITAT Mumbai17 Oct 2024AY 2015-16

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2015-16

For Appellant: Ms. Dinkle Hariya, A.R. &For Respondent: Shri Dinesh A Chourasia, Sr. D.R
Section 133(6)Section 143(3)Section 250

reason stated above. On the contrary the Ld. DR refuted the claim of the Assessee. Considering the reason given by the Assessee for condonation of delay as bonafide, genuine and unintentional, we are inclined to condone the delay, hence the same is condoned. 3. Coming to the merits

Gagan Arora, Delhi vs. ITO Ward 45(1), New Delhi

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

ITA 681/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Oct 2024AY 2017-18

Bench: Shripradip Kumar Kedia & Shri Yogesh Kumar U.S.Ita No.681/Del/2024, A.Y.2017-18) Gagan Arora, Income Tax Officer, Ad-34, 1St Floor, Ward 45(1), Tagore Garden, Vs. New Delhi New Delhi Pan : Afjpa5678Q (Appellant) (Respondent)

Section 271A

record. Ld. CIT(A) while dismissing the appeal filed by the Assessee, observed that the Assessee has not explained the sufficient cause for condonation of delay of 81 days. The Assessee contended before the Ld. CIT(A) that the delay in filing of appeal due to “non-communication and oversight ... filed on time and further contended the Assessee had no malafide intention in not filing the appeal on time, thus, sought for condoning the delay. 5. In our considered opinion, the Ld. CIT(A) should have condoned the delay of 81 days for the reasons stated by the Assessee

Mukand Lal Reoti Prasad, Deoband vs. Income Tax Officer, Ward - 3(3)(4), Deoband

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

ITA 2812/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Oct 2024AY 2017-18

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Shri Sanjay Kumar, Sr. DR
Section 145(3)Section 271ASection 68

against the order of the NFAC, Delhi dated 22.02.2024 pertaining to A.Y 2017-18. 2. At the outset the assessee prayed for the condonation of delay of 41 days on account of murder of the daughter/sister of the partners of the firm by her husband which caused mental harassment ... pressure. We have considered the reasons and condone the delay. 3. The grievances of the assesseeread as under: 1. That, the NFAC has erred in dismissing the appeal of assessee, in ex-party manner, in for non-prosecution without appreciating the material available on record. 2.That, the NFAC has erred

Praveen Bhatia, Gautam Budh Nagar vs. ITO Ward 5(2)(4), Gautam Budh Nagar

The appeal is allowed for statistical purpose

ITA 2068/DEL/2024[2012-13]Status: DisposedITAT Delhi17 Oct 2024AY 2012-13

Bench: Anubhav Sharma & Brajesh Kumar Singhassessment Year: 2012-13 Praveen Bhatia, Vs. Ito Ward 5(2) (4) H.No. 651, Punjabi Mohalla, Dadri, Gautam Buddha Nagar, Dadri S.O., Gautam Budh Nagar, Uttar Pradesh-203207 Pan :Aiapb5033G (Appellant) (Respondent) Assessee By Shri Abhishek Jain, Ca Department By Shri Sanjay Kumar, Sr. Dr.

Section 144Section 147

Authority. As the delay is not, of substantial period, we are inclined to except the plea and admit the appeal for hearing after Condonation of Delay. 4. After going through the Impugned Order of Learned First Appellate Authority we are of considered view that the order clearly

Income Tax Officer, Gonda vs. M/S. Krishi Utpadan Mandi Samiti, Balrampur

In the result, the appeal filed by the Revenue is dismissed as not maintainable

ITA 184/LKW/2023[2013-14]Status: DisposedITAT Lucknow16 Oct 2024AY 2013-14

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 10Section 143(1)Section 250(4)Section 253(3)

Income Tax Act, 1961 (“IT Act” for short). A petition vide letter dated 13/06/2023 has been filed by Revenue seeking condonation of delay and explaining the reason for delay. At the time of hearing before us, learned A.R. of the assessee submitted that the assessee had no objection

The Dol Cooperative Agricultural Service Society Limited, Vpo Aghwani vs. ITO Dharam Shala, Dharamshala

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

ITA 163/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh16 Oct 2024AY 2018-2019

Bench: Shri A.D. Jain & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 163/Chd/2024 "नधा"रण वष" / Assessment Year : 2018-19 The Dol Cooperative Vs. The Ito, बनाम Dharamshala Agricultural Service Society Limited, Vpo Aghwani, Tehsil Jawalamukhi, Kangra Hp "थायी लेखा सं./Pan No: Aadat6246M अपीलाथ"/ Appellant ""यथ"/ Repsondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri Sudhir Sehgal, Advocate राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Jcit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 13.08.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 16.10.2024 आदेश/Order Per Krinwant Sahay, A.M.:

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, JCIT, Sr. DR
Section 143(1)Section 80PSection 80P(2)(a)

Agricultural Service Society Pvt. Ltd, Distt.Kangra 4 3. We have considered the facts and issues mentioned in the aforesaid affidavit and we have condoned the delay. The ld. DR had no objection on this issue. 4. The appeal in this case has been filed on the following grounds : 1) That ... such, there was delay in filing the appeal before the before the CIT(A). 3. The CIT(A) in his wisdom has not condoned the delay in filing the appeal before him and the appeal being late and also according to the CIT(A), there was no sufficient cause

Jadwet Trading Company Private Limited, Port Blair vs. ACIT, Circle - 3(2), Port Blair

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

ITA 961/KOL/2024[2017-2018]Status: DisposedITAT Kolkata16 Oct 2024AY 2017-2018

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 250Section 253(3)Section 253(5)Section 69A

order : October 16th, 2024 ORDER Per Sanjay Awasthi, Accountant Member: This appeal is barred by limitation by 232 days. The appellant has filed condonation of delay petition, along with medical certificate in support of claim that the delay was on genuine grounds and deserves to be condoned. Some portions from

M/S. Mortex Light India Pvt. Ltd. (Successor to Singhvahini Vincom Pvt. Ltd.), Kolkata vs. I.T.O., Ward - 5(1), Kolkata

In the result, this appeal is allowed for statistical purposes

ITA 1459/KOL/2024[2012-2013]Status: DisposedITAT Kolkata16 Oct 2024AY 2012-2013

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Member: In this case there is a delay of 543 days in filing of this appeal. The applicant has filed a request for condonation of delay, supported by an affidavit, as under: “I Adv. Ayush Kumar Dadhich son of Shiv Dayal Dadhich office at 8, Lyons Range, 1” Floor, Kolkata

Vandana Chhajer, Sainthia vs. I.T.O., Ward - 3(2), Suri, Birbhum

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

ITA 1276/KOL/2024[2016-2017]Status: DisposedITAT Kolkata16 Oct 2024AY 2016-2017

Bench: Ms. Madhumita Roy]

Section 143(3)Section 69

written submissions. 3. So far as ITA No. 1186/Kol/2023 is concerned the appeal is barred by limitation by 7 days. An application for condonation of delay has also been filed and the reasons assigned thereto appears to be genuine and thus, the delay is condoned. 4. Both the assessee purchased

M/S. Bhumi Nirman Pvt. Ltd., Kolkata vs. I.T.O., Ward - 10(4), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1166/KOL/2024[2015-2016]Status: DisposedITAT Kolkata16 Oct 2024AY 2015-2016

Bench: Sri Sanjay Garg & Sri Sanjay Awasthi

Section 14ASection 271(1)(c)

order, there is a delay of 293 days. In view of the facts stated hereinabove, the appellant do hereby most respectfully request for condonation of delay.” 1.1. Considering the reasons enunciated in the said petition, the delay is hereby condoned and this appeal is admitted for adjudication. 2. In this

Suman Chhajer, Sainthia vs. ITO, Ward-3(2), Suri

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

ITA 1186/KOL/2023[2016-17]Status: DisposedITAT Kolkata16 Oct 2024AY 2016-17

Bench: Ms. Madhumita Roy]

Section 143(3)Section 69

written submissions. 3. So far as ITA No. 1186/Kol/2023 is concerned the appeal is barred by limitation by 7 days. An application for condonation of delay has also been filed and the reasons assigned thereto appears to be genuine and thus, the delay is condoned. 4. Both the assessee purchased

Hiramani Ajit Kumar Jain, Ratlam vs. ITO-1, Ratlam

The appeal of the assessee is allowed for statistical purpose

ITA 322/IND/2024[2011-2012]Status: HeardITAT Indore16 Oct 2024AY 2011-2012

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Hiramani Ajit Kumar Jain, Income Tax Officer-1, 77, Tashakand Marg, Ratlam Vs. Ratlam (Appellant / Assessee) (Respondent/ Revenue) Pan: Agcph3330A Assessee By Shri Gagan Tiwari, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 16.10.2024 Date Of Pronouncement 16.10.2024 O R D E R

Section 271(1)Section 44ASection 69A

NFAC), Hyderabad for A.Y.201-12. There is a delay of 18 days in filing the present appeal. The assessee has failed an application for condonation of delay which is supported by the affidavit of the Counsel of the assessee. Shri Hiramani Ajit Kumar Jain 2. We have heard ... well as Ld. DR on condonation of delay. The Ld. AR has submitted that due to misplacement of documents comprising part of the appeal the Counsel of the assessee could not file the present appeal within the period of limitation. Therefore, due to inadvertence of misplacement of the documents there