“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

Anand Bhalchandra Kulkarni, Navi Mumbai vs. Principal Commissioner of Income Tax, Pune-1, Pune

In the result, all the appeals of the assessee are rejected as unadmitted being non-maintainable

ITA 1354/PUN/2023[2019-20]Status: DisposedITAT Pune28 Feb 2024AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Ss Viswanethra Ravi () Ita Nos. 1352 To 1357/Pun/2023 Assessment Year: 2017-18 To 2022-23 Anand Bhalchandra Kulkarni, Pr. Cit, Pune-1, G/701 Tulip Afnhb Camp Pmt Building, Swargate, Jalvvayu Vishar Phase-1, Plot-20, Vs. Pune-411037. Sec 20, Kharghar-410210. Pan No. Aanpk 7550 Q Appellant Respondent

For Appellant: Mr. Lokesh K Gandhi (ThroughFor Respondent: Mr. Mirtyunjay Barnwal (Through

Section 115VSection 119Section 119(2)(b)Section 12ASection 132Section 132ASection 143Section 147Section 153ASection 153C

without providing any opportunity of being heard to the appellant. Without prejudice to Ground 1 2. Ld. PCIT erred in not Condoning the delay in filing of revised return u/s 119 (2)(b) of the Act for assessment year 2017-18 without considering that the conditions mentioned in para ... certificate, the period for revising the returns of income for AY 2017-18 to AY 2022-23 expired. Hence, the assessee requested for condonation of delay in filing the revised return of income for assessment years 2017-18 to 2022-23 under the provisions of section

Anand Bhalchandra Kulkarni, Navi Mumbai vs. Principal Commissioner of Income Tax, Pune-1, Pune

In the result, all the appeals of the assessee are rejected as unadmitted being non-maintainable

ITA 1353/PUN/2023[2018-19]Status: DisposedITAT Pune28 Feb 2024AY 2018-19

For Appellant: Mr. Lokesh K Gandhi (ThroughFor Respondent: Mr. Mirtyunjay Barnwal (Through

Section 115VSection 119Section 119(2)(b)Section 12ASection 132Section 132ASection 143Section 147Section 153ASection 153C

Anand Bhalchandra Kulkarni, Navi Mumbai vs. Pricipal Commissioner of Income Tax, Pune-1, Pune

In the result, all the appeals of the assessee are rejected as unadmitted being non-maintainable

ITA 1352/PUN/2023[2017-18]Status: DisposedITAT Pune28 Feb 2024AY 2017-18

For Appellant: Mr. Lokesh K Gandhi (ThroughFor Respondent: Mr. Mirtyunjay Barnwal (Through

Section 115VSection 119Section 119(2)(b)Section 12ASection 132Section 132ASection 143Section 147Section 153ASection 153C

Satya Venkata Chaitanya Mandala, Hyderabad vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Hyderabad

In the result, the appeal of the assessee for A

ITA 597/HYD/2023[2018-19]Status: DisposedITAT Hyderabad28 Feb 2024AY 2018-19

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Sri K.C Devdas, C.AFor Respondent: Shri Shakeer Ahamed, Sr. A.R

Section 132Section 142(1)Section 143(2)Section 153A

have heard both the parties on this preliminary issue. Having regard to the reasons given in the petition, we allow the application for condonation of delay. Accordingly, the delay is condoned and the appeals of the assessee are admitted for hearing. 3. The brief facts of the case are that

Satya Venkata Chaitanya Mandala, Hyderabad vs. Deputy Commissioner of Income Tax, Central Circle-1(1), Hyderabad

In the result, the appeal of the assessee for A

ITA 593/HYD/2023[2017-18]Status: DisposedITAT Hyderabad28 Feb 2024AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Sri K.C Devdas, C.AFor Respondent: Shri Shakeer Ahamed, Sr. A.R

Section 132Section 142(1)Section 143(2)Section 153A

Tbr Infra Pvt Ltd, Alampuram vs. Deputy Commissioner of Income Tax, Circle-1, Rajahmundry

In the result, appeal of the assessee is dismissed

ITA 5/VIZ/2024[2019-20]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.05 /Viz/2024 (ननधधारण वर्ा / Assessment Year : 2019-20) Tbr Infra (P) Ltd. Vs. Dy.Commissioner Of D.No.7-130/2 Income Tax Nh-16, Alampuram Circle-1 West Godavari Dist. Rajahmundry [Pan : Aafct6445E] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Aparna Villuri, DR

Section 139(1)Section 143(1)

No.ITBA/NFAC/S/250/2023-24/1054359987(1) dated 14.07.2023 for the Assessment Year (A.Y.) 2019-20 with the delay of 112 days. The assessee filed a petition for condonation of delay, submitting that Sri T.Karthik, who joined as accountant in the assessee company on 12.02.2021 and handled all financial, tax related matters, left the company ... delay of 112 days. The assessee submitted that the delay in filing the appeal is neither intentional nor deliberate and hence pleaded to condone the delay and admit the appeal for hearing. 2. We have gone through the condonation petition filed by the assessee. In the instant case, the order

Bantu Pilli Govindarao, Anandapuram vs. Joint Commissioner of Income Tax, Range-2, Visakhapatnam

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

ITA 306/VIZ/2023[2016-17]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.306/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2016-17) Bantu Pilli Govindarao Vs. Joint Commissioner Of 1-276, Vemulavalasa Income Tax Bpv Kallalu, Anandapuram Range-2 Visakhapatnam Visakhapatnam [Pan : Alipg7088F] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Aparna Villuri, DR

Section 269SSection 271Section 271D

Hearing : 20.02.2024 घोर्णध की तधरीख/Date of Pronouncement : 28.02.2024 आदेश /O R D E R Per Shri Duvvuru RL Reddy, Judicial Member : Condonation of Delay : This appeal is filed by the assessee against the order of Commissioner of Income Tax (Appeals) [CIT(A)], National Faceless Appeal Centre (NFAC), Delhi ... short ‘Act’) dated 30.05.2022 for the Assessment Year (A.Y.) 2016-17 with the delay of 60 days. The assessee filed petition for condonation of delay, submitting that the assessee is not educated and not 2 I.T.A. No.306/Viz/2023, A.Y.2016-17 Bantupilli Govinda Rao, Visakhapatnam having knowledge of using a computer, hence, engaged

Malleswara Rao Alamuri (Late), Rep by Wife and L/R Alamuri Lakshmi, Vijayawada vs. Income Tax Officer, Ward-1(1), Vijayawada

In the result, appeal of the assessee is dismissed

ITA 123/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No. 123/Viz/2023 ("नधा"रण वष" / Assessment Year : 2017-18) (Late) Malleswara Rao Alumuri, Vs. Income Tax Officer, Rep. By Wife & L/R Alamuri Ward-1(1), Lakshmi, Vijayawada. D.No. 10-14/2-32, Akulavari Street, Mallikharjunapet, One Town, Vijayawada, Andhra Pradesh – 520001. Pan: Aldpa 7438 G (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri C. Subrahmanyam, Ar ""याथ" क" ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr

For Appellant: Sri C. Subrahmanyam, ARFor Respondent: Dr. Satyasai Rath, CIT-DR

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 263

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 contents of affidavit are extracted herein below for reference: “1. The petitioner is the wife and legal representative ... find that the assessee was prevented by a reasonable and sufficient cause to file the appeal within the stipulated time. Therefore, we hereby condone the delay of 337 days in filing the appeal before the Tribunal and proceed to adjudicate the appeal on merits. 4. Briefly stated the facts

The Konayapalem Pacs Ltd., Chandarlapadu Mandal vs. ITO, Ward-1(3), Vijayawada

In the result, appeal of the assessee is dismissed

ITA 126/VIZ/2022[2017-18]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.126/Viz/2022 ("नधा"रण वष" / Assessment Year : 2017-18) The Konayapalem Primary Vs. Income Tax Officer, Agricultural Cooperative Credit Ward-(3), Society Limited, Konayapalem Vijayawada. Village, Chandarlapadu Mandal, Krishna District, Andhra Pradesh – 521182. Pan: Aacat 6987 G (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri Asrss Siva Prasad, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri ASRSS Siva Prasad, ARFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 139Section 139(1)Section 142(1)Section 144Section 80A(5)Section 80PSection 80P(2)Section 80P(2)(a)

belated filing of the appeal, the Ld. AR drawn my attention to the affidavit filed by the assessee along with petition seeking for condonation of delay and read out the contents of the affidavit which is as under: “I, Mekala Srinivasa Rao, Secretary to the Konayapalem Primary Agricultural Cooperative Credit ... reasonable and sufficient cause in filing the appeal beyond the prescribed limit with a delay of 97 3 days. Therefore, I hereby condone the delay of 97 days in filing the appeal before the Tribunal and proceed to adjudicate the appeal on merits in the following paragraphs. 4. Briefly stated

M/S Laxminarayan Associatesbhopal, Bhopal vs. The ITO 3(2), Bhopal

In the result, Quantum appeal is partly allowed and penalty appeal is allowed

ITA 83/IND/2023[2017-18]Status: DisposedITAT Indore28 Feb 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 271ASection 40Section 68

There is a delay of three days in filing the present appeal. The assessee has filed an application for condonation of delay explaining the cause of delay of three days. 10. We have heard Ld. AR as well as Ld. DR and considered the reason explained by the assessee

M/S Laxminarayan Associatesbhopal, Bhopal vs. The ITO 3(2), Bhopal

In the result, Quantum appeal is partly allowed and penalty appeal is allowed

ITA 215/IND/2023[2017-18]Status: DisposedITAT Indore28 Feb 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 271ASection 40Section 68

Gurubasappa Shahapur, Bijapur vs. Income Tax Officer, Ward-2, Bijapur

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

ITA 172/BANG/2024[2017-18]Status: DisposedITAT Bangalore28 Feb 2024AY 2017-18

Bench: Shri George George K & Shri Chandra Poojariassessment Year : 2017-18 Shri. Gurubasappa Shahapur, Vs. Ito, Lh Bidariakkamahadevi Road, Ward – 2, Bijapur – 586 101, Bijapur. Karnataka. Pan : Cgxp 7107 P Appellant Respondent Assessee By : Smt. Prathibha R, Advocate Revenue By : Shri. Ganesh R. Ghale, Advocate – Standing Counsel For Revenue. Date Of Hearing : 28.02.2024 Date Of Pronouncement : 28.02.2024

For Appellant: Smt. Prathibha R, AdvocateFor Respondent: Shri. Ganesh R. Ghale, Advocate – Standing Counsel for Revenue

Section 250

Assessment Year is 2017-18. 2. There is a delay of 22 days in filing this appeal. Assessee has filed a petition for condonation of delay accompanied by affidavit stating therein the reasons for late filing of this appeal. We have perused the reasons stated in the affidavit for belated ... view that there is reasonable cause and no latches can be attributed to the assessee for belated filing of this appeal. Hence, we condone the delay of 22 days in filing this appeal and proceed to dispose off the same on merits. Page 2 of 3 3. At the very

Sunil Tibrewal Foundation, Bhiwandi, Thane vs. CIT (Exemptions), Pune

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

ITA 3520/MUM/2023[2023-24]Status: DisposedITAT Mumbai28 Feb 2024AY 2023-24

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Ms. Anushree GuptaFor Respondent: Shri Dr. Kishor Dhule

Section 10Section 11(7)Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

Foundation ITA no.3520/Mum/2023 2. The present appeal is delayed by 128 days. Along with the appeal the assessee has filed an application seeking condonation of delay in filing the present appeal duly supported by the affidavit of the trustee. In the aforesaid application, the assessee has made the following submissions ... being preferred on 29.09.2023 with a delay of 125 days. The reasons for delay are explained herewith and in the petition for condonation of delay annexed to this Affidavit. 4. The Appellant had filed an application for regular approval under clause (iii) to first proviso to section

Premji Bhuralal Gala, Mumbai vs. NFAC, Delhi

In the result, appeal of the assessee is allowed on the validity of the re-opening u/s

ITA 3081/MUM/2022[2012-13]Status: DisposedITAT Mumbai28 Feb 2024AY 2012-13

Bench: Your Honors Should Have Been Filed Within 60 Days Of Receipt Of The Order Of Cxit(A) But The Same Could Not Be Done.

Section 143(1)Section 143(3)Section 147Section 69C

account of cash loan has been made. At the outset, appeal of the assessee is delayed by 437 days. In the petition for condonation of delay, the assessee has stated as under: “Sub: Request for Condonation of Ι.Τ.Α NO. 3081/MUM/2022 Respected Sir, It has been brought ... ignorant on the procedure as newly introduced, I feel that I have committed the mistake and accordingly I request your honors to kindly condone the delay as pointed out by your honors and oblige.” 2 AY. 2012-13 Premji Bhuralal Gala 2. After considering the aforesaid reasons as stated

Sh. Gagan Suri, Panchkula vs. ACIT, Panchkula Circle, Panchkula

In the result, Ground No. 1 of the assessee’s appeal is allowed in terms of above directions

ITA 311/CHANDI/2023[2014-15]Status: DisposedITAT Chandigarh27 Feb 2024AY 2014-15

Bench: SHRI. SANJAY GARG (Judicial Member), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Surinder Mahajan, CAFor Respondent: Shri Rohit Sharma, CIT DR

Section 142(1)Section 143(3)Section 147Section 148Section 27Section 28Section 68

filing the appeal has been established by the assessee. It was submitted that the appeal has been dismissed at the very threshold without condonation of delay for which there was sufficient cause and there is no finding recorded by the Ld. CIT(A) on the merits of the case ... first ground of appeal taken by him wherein he has challenged the action of the Ld. CIT(A) in refusing to condone the delay in filing the appeal. It is an admitted fact as apparent from the affidavit placed on record and not in dispute that there are various Court

Vinayagam Chettiar Sekar, Chennai vs. ITO, Non Corporate Ward-19(3), Chennai

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

ITA 1425/CHNY/2023[2017-18]Status: DisposedITAT Chennai27 Feb 2024AY 2017-18

Bench: Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1425/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Shri. Vinayagam Chettiar The Income Tax Officer, Sekar, V. Non Corporate Ward -19(3), No. 87A, Wanaparthy Block, Market Lane, No. 121, M G Road, Alandur, Nungambakkam, Chennai – 600 016. Chennai – 600 034. [Pan: Aajps-6500-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. T. Vasudevan, Advocate : Shri. D. Hema Bhupal, Jcit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 27.02.2024 घोषणा क" तारीख/Date Of Pronouncement : 27.02.2024 आदेश /O R D E R

For Appellant: Shri. T. Vasudevan, Advocate

Section 69

outset, we find that there is a delay of 72 days in appeal filed by the assessee, for which petition for condonation of delay along with reasons for delay has been filed. After considering :-2-: ITA. No: 1425/Chny/2023 the petition filed by the assessee and also hearing both the parties

Sarika Sachdeva, New Delhi vs. ACIT Central Circle-01, New Delhi

In the result, Appeal filed by the Assessee in ITA Nos

ITA 65/DEL/2021[2014-15]Status: DisposedITAT Delhi27 Feb 2024AY 2014-15

Bench: or during the course of hearing of the appeal.”

Section 143Section 143(3)Section 153ASection 69A

Moto Writ Petition No.03/2020 Extending Limitation due to COVID-19 is still operative and therefore no separate application for condonation of delay is being filed with the present appeal.” “1. The Order paved by the Ld CTT (Appeals) is opposed to land facts of the case. 2. That ... Order dated 23.01.2020 Suo Moto Writ Petition No.03/2020 Extending Limitation due to COVI-19 is still operative and therefore no separate application for condonation of delay is being filed with the present appeal.” 3. The Ld. Counsel for the Assessee submitted that the Ld. CIT(A) erred in upholding

Sarika Sachdeva, New Delhi vs. ACIT Central Circle-01, New Delhi

In the result, Appeal filed by the Assessee in ITA Nos

ITA 64/DEL/2021[2013-14]Status: DisposedITAT Delhi27 Feb 2024AY 2013-14

Bench: or during the course of hearing of the appeal.”

Section 143Section 143(3)Section 153ASection 69A

Sarika Sachdeva, New Delhi vs. ACIT Central Circle-01, New Delhi

In the result, Appeal filed by the Assessee in ITA Nos

ITA 63/DEL/2021[2012-13]Status: DisposedITAT Delhi27 Feb 2024AY 2012-13

Bench: or during the course of hearing of the appeal.”

Section 143Section 143(3)Section 153ASection 69A

Assistant Commissioner of Income Tax, Circle - 7(1), Kolkata vs. Britannia Industries Limited, Kolkata

In the result, the appeal of the revenue is partly allowed

ITA 888/KOL/2023[2018-2019]Status: DisposedITAT Kolkata26 Feb 2024AY 2018-2019

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. No.888/Kol/2023 Assessment Year: 2018-19 Assistant Commissioner Of Income-Tax, ………. Appellant Circle-7(1), Kolkata. Vs. Britannia Industries Ltd. (Pan: Aabcb2066P) …………….. Respondent Appearances By: Shri Abhijit Kundu, Cit (Dr) Appeared For Appellant Shri Akkal Dudhewala, Fca Appeared For Respondent . Date Of Concluding The Hearing : 19.12.2023 Date Of Pronouncing The Order : 26.02.2024 Order Per Manish Borad: This Appeal Filed By The Revenue Pertaining To The Assessment Year (In Short “Ay”) 2018-19 Is Directed Against The Order Passed U/S 250 Of The Income Tax Act, 1961 In Short The “Act”) By Ld. Commissioner Of Income-Tax, Nfac, Delhi [In Short Ld. “Cit(A)”] Dated 24.03.2023 Arising Out Of The Assessment Order Framed U/S 143(3) Read With Sections 143(3A) & 143(3B) Of The Act By Ao, Income Tax Department, National E-Assessment Centre, Delhi Dated 22.03.2021. 2. There Is A Delay Of 93 Days In Filing The Instant Appeal. An Application For Condonation Of Delay Has Been Filed By The Revenue Which Is Placed On Record. After Perusal Of The Same, We Notice That I.T.A. No. 888/Kol/2023 A Y: 2018-19, Britannia Industries Ltd. Though The Impugned Order Was Passed On 24.03.2023 But The Same Was Received In The Office Of The Ld. Cit(A), Kolkata On 04.08.2023 To This Effect A Certificate Is Filed By The Revenue Authorities. Considering This To Be Reasonable Cause & In The Larger Interest Of Justice, We Condone The Delay & Admit The Appeal For Adjudication.

Section 143(3)Section 250Section 35

National e-Assessment Centre, Delhi dated 22.03.2021. 2. There is a delay of 93 days in filing the instant appeal. An application for condonation of delay has been filed by the revenue which is placed on record. After perusal of the same, we notice that I.T.A. No. 888/Kol/2023 ... effect a certificate is filed by the revenue authorities. Considering this to be reasonable cause and in the larger interest of justice, we condone the delay and admit the appeal for adjudication. 3. Revenue has raised following two grounds of appeal: “1. Disallowance u/s. 35(2AB) amounting to Rs.26