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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

Bhaskar Reddy Nandyala Hanumantha Reddygari, Bangalore vs. DCIT, Central Circle-1(1), Bengaluru

In the result, all these appeals are partly allowed for statistical purposes

ITA 1161/BANG/2024[2013-14]Status: DisposedITAT Bangalore18 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

For Appellant: Sri Prashanth M.V., A.RFor Respondent: Sri D.K. Mishra, D.R
Section 144BSection 147Section 148

Annexure-A ITA Nos.1161 to 1163/Bang/2024 Bhaskar Reddy Nandyala Hanumantha Reddygari, Bangalore Page 2 of 11 3. The Assessee humbly prays to condone the delay in filing of appeal before CIT (A) and non-compliances for submission of necessary documents during CIT(A) proceedings due the reasons cited in PARA ... Notice. 2.8 Further, he observed that the assessee even after filing of appeal with delay for the relevant AYs has not filed any condonation of delay application and affidavit, aiming to justify the significant delay of more than 1 year in filing the appeal for relevant AYs. Which shows that

Rohan Hemant Thakkar, Mumbai vs. ITO 22(3)(2), Bandra Kurla Complex

ITA 1823/MUM/2024[2011-2012]Status: DisposedITAT Mumbai18 Jul 2024AY 2011-2012

Bench: Shri Satbeer Singh Godara & Shri Girish Agrawal

For Respondent: Shri Vimal Punmiya, CA
Section 143(3)Section 147Section 148Section 234ASection 54F

admitting appeal of the appellant on the pretext that there is delay of 1106 days and appellant failed to make application for condonation of delay in filing appeal. Reasons assigned by him are wrong and insufficient in not admitting appeal of the appellant. 2. On the facts ... appeal of the assessee at the first appellate stage owing to delay of 1106 days, since assessee failed to make application for condonation of delay in filing of the said appeal before the ld. CIT(A). In this respect, we perused the order of the ld. CIT(A) and taken

Imperial Auto Inudstries Limited, Delhi vs. DCIT, Delhi

ITA 3927/DEL/2023[2020-21]Status: DisposedITAT Delhi18 Jul 2024AY 2020-21

Bench: Shri G. S. Pannu & Ms. Madhumita Royi.T.A. No. 3927/Del/2023 (Assessment Year : 2020-21) M/S. Imperial Auto Vs. Asst. Director Of Income Tax Industries Ltd., Centralized Processing Plot No.202, Kushal Cell, Bengaluru Bazar, 32-33, Nehru Place, New Delhi-110019 Pan: Aaaci 0645 J (Appellant) .. (Respondent)

For Appellant: Dr. Rakesh Gupta, Adv. And Mr. Deepesh Garg, AdvFor Respondent: Shri T. James Singson, CIT-D.R
Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 250

proceedings, including filing of the appeal against the intimation/assessment order. Further, from the contents of the petition filed by the assessee for condonation of delay, it is seen that the appellant has chosen not to file the appeal against the intimation u/s 143(1) of the Act, because ... only an afterthought. Thus, there is no merit in the reasons given by ) the appellant in the petition for condonation of delay in filing of the appeal. Be that as it may, coming back to the legal position evolved by the decision of various High Courts, including

Aman Infraproperties P. Ltd, Lucknow vs. ACIT Range-1, Lucknow

In the result, the appeal of the assessee in ITA

ITA 387/LKW/2023[2015-16]Status: DisposedITAT Lucknow16 Jul 2024AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

For Appellant: Shri Shubham Rastogi, C.AFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 143(3)Section 154Section 234ESection 250Section 37

duly explained before the Lower Authorities. 2. There is delay in filing of this appeal and the assessee has filed application for condonation of delay. The ld. D.R. has no objection to the prayer made by the assessee for condonation of delay. Accordingly, we condone the delay and admit this

Aman Infraproperties P. Ltd, Lucknow vs. ACIT Range-1, Lucknow

In the result, the appeal of the assessee in ITA

ITA 386/LKW/2023[2015-16]Status: DisposedITAT Lucknow16 Jul 2024AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

For Appellant: Shri Shubham Rastogi, C.AFor Respondent: Shri Sanjeev Krishna Sharma, D.R
Section 143(3)Section 154Section 234ESection 250Section 37

duly explained before the Lower Authorities. 2. There is delay in filing of this appeal and the assessee has filed application for condonation of delay. The ld. D.R. has no objection to the prayer made by the assessee for condonation of delay. Accordingly, we condone the delay and admit this

Shanti Multilink Pvt. Ltd, Ahmedabad vs. The Income Tax Officer, Ward-4(1)(3), Ahmedabad

In the result, the appeal filed by the Assessee is treated as allowed for statistical purposes

ITA 31/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad16 Jul 2024AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.31/Ahd/2023 "नधा"रण वष" /Assessment Year : 2016-17 Shanti Multilink Pvt.Ltd. The Income Tax Officer बनाम/ A-215, Siddhi Vinayak Tower Ward-4(1)(3) Off S.G. Road Ahmedabad-380 015 V/S. Makarba Ahmedabad – 380 051 "थायी लेखा सं./Pan: Aahcs 1972 M अपीलाथ"/ (Appellant) ….. "" यथ"/ (Respondent) Assessee By : Shri Vivek Chavda, Ar Revenue By : Shri Ashok Kumar Suthar, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 15/07/2024 घोषणा क" तार"ख /Date Of Pronouncement: 16/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Assessee As Against The Order Dated 09/11/2022 Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “The Ld.Cit(A)” In Short], Arising Out Of The Assessment Order Dated 28/12/2018 Passed By The Assessing Officer (Ao) Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Relevant To The Assessment Year (Ay) 2016-17. Shanti Multilink Pvt.Ltd. Vs. Ito Asst. Year : 2016-17

For Appellant: Shri Vivek Chavda, ARFor Respondent: Shri Ashok Kumar Suthar, Sr.DR
Section 143(3)Section 40A(2)(b)

referred to as "the Act") relevant to the Assessment Year (AY) 2016-17. Shanti Multilink Pvt.Ltd. vs. ITO Asst. Year : 2016-17 2 Condonation of delay: 2. The assessee has filed an application for condonation of delay of 3 days in filing the appeal before us. The assessee-company submitted

Sunilkumar Rajendra Rai, Nagpur vs. ITO, Ward-1(4), Nagpur

In the result, appeals filed by the assessees are allowed

ITA 286/NAG/2023[2013-14]Status: DisposedITAT Nagpur16 Jul 2024AY 2013-14

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

For Appellant: NoneFor Respondent: Shri Abhay Y.Marathe, Sr.Dr
Section 200Section 200ASection 234ESection 250

no.286/Nag./2023 The assessee has raised following grounds of appeal:– 2. “ Grounds of Appeal Tax Effect 1. The learned CIT(A) erred in condoning the delay 0 in filing the appeal. 2. The order passed u/s 200 r.w.s. 234E of I,.T. Act 39,200 1961 imposing penalty u/s 234E ... file the appeal at the belated stage of the proceedings. The assessee has a primafacie good case on merit hence the application for condonation of delay needs to be allowed and the delay needs to be condoned in the interest of justice. 7. Assessee places reliance on the decision

Subhashchand Sunderlal Chankak, Nagpur vs. Assistant Commissioner of Income Tax, Circle-1, Nagpur

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

ITA 33/NAG/2021[2006-07]Status: DisposedITAT Nagpur16 Jul 2024AY 2006-07

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

For Appellant: Shri K.M. GuptaFor Respondent: Shri Abhay Y. Marathe
Section 147Section 250Section 68

assessee has filed Affidavit, the contents of which are reproduced below:– “AFFIDAVIT ON BEHALF OF APPELLANT / DEPONENT IN SUPPORT OF APPLICATION FOR CONDONATION OF DELAY OF 2006 DAYS IN FILING APPEAL The Deponent named above does hereby take oath and state on solemn affirmation as under ... counsel as per instructions given by me. I further say and submit that the factual submissions and aspect made in the application for condonation of delay in filing present appeal and instant appeal is true and correct to my personal knowledge and beliefs and legal submissions if any made

Shri Subhashchand Chandak, Nagpur vs. Assistant Commissioner of Income Tax, Circle-1, Nagpur

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

ITA 26/NAG/2021[2006-07]Status: DisposedITAT Nagpur16 Jul 2024AY 2006-07

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

For Appellant: Shri K.M. GuptaFor Respondent: Shri Abhay Y. Marathe
Section 147Section 250Section 68

assessee has filed Affidavit, the contents of which are reproduced below:– “AFFIDAVIT ON BEHALF OF APPELLANT / DEPONENT IN SUPPORT OF APPLICATION FOR CONDONATION OF DELAY OF 2006 DAYS IN FILING APPEAL The Deponent named above does hereby take oath and state on solemn affirmation as under ... counsel as per instructions given by me. I further say and submit that the factual submissions and aspect made in the application for condonation of delay in filing present appeal and instant appeal is true and correct to my personal knowledge and beliefs and legal submissions if any made

The Telangana Nongazetted Officers Mutually Aided Coop Housing Soceity Limited, Hyderabad vs. ITO., Ward-5(1), Hyderabad

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

ITA 52/HYD/2024[2019-20]Status: DisposedITAT Hyderabad16 Jul 2024AY 2019-20

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.52/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2019-20) The Telangana Non- Vs. Income Tax Officer Gazetted Officers Mutually Ward 5(1) Aided Coop Housing Hyderabad Society Ltd Pan:Aacat4191J (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate Ravindra Chenji राज" व "ारा/Revenue By:: Smt. Sheetal Sarin, Dr सुनवाई की तारीख/Date Of Hearing: 16/07/2024 घोषणा की तारीख/Pronouncement: 16/07/2024 आदेश/Order

For Appellant: Advocate Ravindra ChenjiFor Respondent: : Smt. Sheetal Sarin, DR
Section 143(1)Section 80PSection 80P(2)(f)

appeal which caused a delay of 230 days. The delay is neither intentional nor wanton of any undue benefit, therefore, requested to condone the delay. The learned CIT (A) after considering the submissions of the assessee and also taking note of certain judicial precedents rejected the reasons given ... assessee and dismissed the appeal as non-est. Therefore, submitted that a direction may be given to the learned CIT (A) to condone the delay and the matter may be set aside to the file of the learned CIT (A) to decide the issue on merit. 6. The learned

Stl Extrusion Pvt Ltd, Indore vs. Assistant Commissioner of Income Tax 4(1), Indore

ITA 116/IND/2024[2012-13]Status: DisposedITAT Indore16 Jul 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Stl Extrusion Pvt. Ltd, Acit-4(1), 475 Jawahar Marg, Indore Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaecs3555M Assessee By Ms. Shreya Jain, Ar Revenue By Shri Ram Kumar Yadav, Cit-Dr Date Of Hearing 15.07.2024 Date Of Pronouncement 16.07.2024 O R D E R

Section 250

condoned and appeal of the assessee may be admitted for adjudication. On the other hand the Ld. DR has not seriously opposed the condonation of delay by considering the fact that the business of the assessee was closed in the year 2017 itself and both the A.O as well

Veena Sharma, Jaipur vs. Income Tax Officer, Jaipur

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

ITA 376/JPR/2024[2013-2014]Status: DisposedITAT Jaipur16 Jul 2024AY 2013-2014

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

For Appellant: Sh. Saurav Harsh, AdvFor Respondent: Sh. Anoop Singh, Addl. CIT (V.C)
Section 147Section 148Section 69C

delay of 04 days in filing of the appeal by the assessee. Ld. AR of the assessee presented an application for condonation of delay on the following grounds: “The humble assessee appellant applicant respectfully prays for the condonation of delay in filling of Appeal before the Hon'ble Income ... appellant as the delay was not intentional and due to unavoidable circumstances. That in these circumstances we request your honour’s to kindly condone the delay and oblige.” 5. During the course of hearing, the ld. DR did not object to assessee’s application for condonation of delay and prayed

Veena Sharma, Jaipur vs. Income Tax Officer Ward 7(3), Jaipur

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

ITA 375/JPR/2024[2011-2012]Status: DisposedITAT Jaipur16 Jul 2024AY 2011-2012

Bench: the Hon'ble Income-tax Appellate Tribunal for the following reason: 3

For Appellant: Sh. Saurav Harsh, AdvFor Respondent: Sh. Anoop Singh, Addl. CIT (V.C)
Section 147Section 148Section 69C

delay of 04 days in filing of the appeal by the assessee. Ld. AR of the assessee presented an application for condonation of delay on the following grounds: “The humble assessee appellant applicant respectfully prays for the condonation of delay in filling of Appeal before the Hon'ble Income ... appellant as the delay was not intentional and due to unavoidable circumstances. That in these circumstances we request your honour’s to kindly condone the delay and oblige.” 5. During the course of hearing, the ld. DR did not object to assessee’s application for condonation of delay and prayed

Jawaharlal Nehru Shekshanik and Samajik Sansthan, Jaipur vs. Exemption Ward 1, Jaipur

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

ITA 630/JPR/2023[2016-17]Status: DisposedITAT Jaipur16 Jul 2024AY 2016-17
For Appellant: Sh. Tarun Mittal, CAFor Respondent: Sh. A. S. Nehra, Add. CIT
Section 143(3)Section 250

filing the present appeal by 23 days. In support of that delay the ld. AR of the contended as under: Sub: Application seeking Condonation of delay- Jawaharlal Nehru Shekshanik and Samajik Sansthan- Assessment Year 2016-17 In the aforesaid context, it is humblysubmitted that order u/s 250 was passed ... herewith. In the circumstances of the matter it is humbly prayed to the Hon’ble Bench to please accept the application/prayer of the condonation of delay which is merely of 23 days and to please be kind enough to direct the listing of the appeal for disposal on the merits

Telebyte Technologies Pte Limited, Mumbai vs. Commissioner of Income Tax(Appeal)-58, Mumbai

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

ITA 2170/MUM/2024[2018-19]Status: DisposedITAT Mumbai16 Jul 2024AY 2018-19

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Smt. Kavitha Rajagopal, Hon’Ble

For Appellant: Shri Aditya Ramchandran, A/RFor Respondent: Shri Anil Sant, Sr. D/R

11/Mum/2024 & I.T.A. No. 2170/Mum/2024 2 2. The captioned appeals are filed after the expiry of period of limitation with an application for condonation of delay. We have carefully considered the reasons for delay in filing of the appeal and we are convinced that the assessee was prevented by sufficient cause

Telebyte Technologies Pte Limited, Mumbai vs. International Taxation 4(1)(2), Mumbai

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

ITA 11/MUM/2024[2017-18]Status: DisposedITAT Mumbai16 Jul 2024AY 2017-18

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Smt. Kavitha Rajagopal, Hon’Ble

For Appellant: Shri Aditya Ramchandran, A/RFor Respondent: Shri Anil Sant, Sr. D/R

11/Mum/2024 & I.T.A. No. 2170/Mum/2024 2 2. The captioned appeals are filed after the expiry of period of limitation with an application for condonation of delay. We have carefully considered the reasons for delay in filing of the appeal and we are convinced that the assessee was prevented by sufficient cause

Western Outdoor Interactive Pvt Ltd, Mumbai vs. Assessement Unit, Income Tax Department Asstt Comm. of Income Tax, Circle-16(1), Mumbai

ITA 2474/MUM/2022[2018-19]Status: DisposedITAT Mumbai16 Jul 2024AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Dhanesh Bafna, Shri AmolFor Respondent: Shri Himanshu Sharma, CIT-DR
Section 143(3)Section 234ASection 244ASection 270ASection 40

order dated 22.09.2017 and therefore, filed their revised return on 17.02.2021 of the merged entity. The ld. AR submitted that the petition for condonation of delay in filing the revised return is made before the CBDT under section 119 and the same is pending. 25. The ld. DR submitted that ... parties and perused the material on record. From the report of the AO, we notice that the assessee has made an application for condonation of delay before CBDT for filing the revised return belatedly and that the assessee is yet to receive order from the CBDT condoning the delay. Western

Western Outdoor Interactive Private Limited, Mumbai vs. Asstt. Comm. of Income Tax, Circle-16(1), Mumbai

ITA 2461/MUM/2022[2017-2018]Status: DisposedITAT Mumbai16 Jul 2024AY 2017-2018

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Dhanesh Bafna, Shri AmolFor Respondent: Shri Himanshu Sharma, CIT-DR
Section 143(3)Section 234ASection 244ASection 270ASection 40

order dated 22.09.2017 and therefore, filed their revised return on 17.02.2021 of the merged entity. The ld. AR submitted that the petition for condonation of delay in filing the revised return is made before the CBDT under section 119 and the same is pending. 25. The ld. DR submitted that ... parties and perused the material on record. From the report of the AO, we notice that the assessee has made an application for condonation of delay before CBDT for filing the revised return belatedly and that the assessee is yet to receive order from the CBDT condoning the delay. Western

Asst. Commissioner of Income Tax, Vijayawada vs. Fysolate Technologies, Vijayawada

In the result, appeal of the Revenue is dismissed

ITA 182/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam15 Jul 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.182/Viz/2023 (िनधा"रण वष" / Assessment Year : 2017-18) Assistant Commissioner Of Vs. Fysolate Technologies, Income Tax, Vijayawada. Vijawayada. Pan: Aacff5633L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Mithilesh Sannareddy ""याथ" क" ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr सुनवाई क" तारीख / Date Of Hearing : 16/04/2024 घोषणा क" तारीख/Date Of : 15/07/2024 Pronouncement O R D E R

For Appellant: Sri Mithilesh SannareddyFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 10ASection 143(2)Section 143(3)Section 92C

filing of the appeal, the Ld. DR drew our attention to the affidavit filed by the Revenue along with a petition seeking for condonation of delay and read out the contents of the affidavit which is as under: “ 1….. 2…... 3…… 4. The jurisdictional Range Head, who is holding regular ... stated herein above. It is submitted that there are good grounds to succeed in the appeal. It is therefore just and necessary to condone the delay in filing the above appeal. 7……” 3. On perusal of the contents of the affidavit filed by the Revenue as well as the submission

M/S Kadirur Service Co-Op Bank Ltd, Kannur vs. ITO Ward 2, Kannur

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

ITA 104/COCH/2023[2009-10]Status: DisposedITAT Cochin15 Jul 2024AY 2009-10

Bench: Smt. Beena Pillai & Shri Waseem Ahmedassessment Year : 2009-10 M/S. Kadirur Service Co- Operative Bank Ltd., The Income Tax Kadirur, Officer, Thalassery, Ward – 2, Kannur, Kannur. Kerala – 670 642. Vs. Pan: Aaffk6859E Appellant Respondent : Shri Arun Raj .S, Assessee By Advocate Revenue By : Shri Ilayaraja K.S, Sr. Dr

For Respondent: Shri Arun Raj .S
Section 142(1)Section 143(3)Section 51Section 80p

submitted that, there is delay of 12 days in filing the present appeal before this Tribunal. The Ld.AR furnished affidavit for condonation of delay that reads as under: Page 2 of 16 Page 3 of 16 Page 4 of 16 2.1 In view of the above, the assessee could ... submissions advanced by both sides in the light of records placed before us. 2.3 In our opinion there is sufficient cause to condone the delay as observed by Hon’ble Supreme Court in case of Collector Land Acquisition Vs. Mst. Katiji & Ors., reported in (1987) 167 ITR 471 in support