“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

Microland Foundation, Bangalore vs. The Income Tax Officer (Exemptions), Ward-2, Bangalore

In the result, the appeals filed by the assessee are dismissed

ITA 410/BANG/2022[2017-18]Status: DisposedITAT Bangalore01 Sept 2022AY 2017-18

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: --- None ---For Respondent: Sri.K.R.Narayana, Addl.CIT-DR

Section 11(2)Section 13(9)Section 139(1)Section 143(1)Section 143(3)Section 3

confirmed the view taken by the Assessing Officer. However, the CIT(A) noticed that the assessee had filed condonation application (for condoning the delay in filing Form 10) before the Commissioner of Income- tax (Exemption) and the same is pending. Consequently, the CIT(A) directed the A.O. to grant ... learned DR and perused the material on record. As rightly pointed out by the learned DR, the assessee has filed condonation petition for condoning the delay in filing Form No.10 before the CIT(Exemption). If the CIT(Exemption) condones the delay in filing Form No.10, necessary benefit of exemption

Atlantic Bio Medical Pvt. Ltdltd, Mumbai vs. DCIT 9(1) (4) CPC, Mumbai

ITA 117/MUM/2022[2017-18]Status: DisposedITAT Mumbai25 Aug 2022AY 2017-18

Bench: Shri Kuldip Singh & Shri Om Prakash Kantassessment Year: 2017-18

For Appellant: Shri K. Gopal, A.R. &For Respondent: Shri Manoj Sinha, Sr. A.R

Section 143(1)Section 43BSection 80I

appeal on the ground 2 M/s. Atlantic Bio Medical Pvt. Ltd. that assessee has failed to bring on record any sufficient cause to condone the delay. 2. Assessee by moving an application supported with affidavit filed by Mr. Varun Ravi Vazirani sought to condone the delay of 314 days ... under the bonafide belief of the accountant. 3. However, on the other hand, the Ld. D.R. for the Revenue opposed the application for condonation of delay on the ground that the late filing of appeals in this case is apparently malafide due to callous attitude of the assessee and prayed

G.D. Shah Charitable Trust, Mumbai vs. CIT (E), Mumbai

The appeal of the assessee is dismissed as withdrawn

ITA 1398/MUM/2022[2022-23]Status: DisposedITAT Mumbai24 Aug 2022AY 2022-23

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2022-23 G.D. Shah Charitable Trust, The Commissioner Of Income Tax 372, A & B, Deep Ashish, 9Th (Exemption), Road, Shantabai Ambre Marg, Vs. Mumbai. Chembur, Mumbai-400071. Pan No. Aabtg 1766 A Appellant Respondent Assessee By : Mr. Sumit Mantri Revenue By : Mr. Kailash Kanojia, Cit-Dr Date Of Hearing : 24/08/2022 Date Of Pronouncement : 24/08/2022

For Appellant: Mr. Sumit MantriFor Respondent: Mr. Kailash Kanojia, CIT-DR

Section 12A

withdrawal of the appeal by the , but in view of the withdrawal of the appeal by the assessee, we are not adjudicating upon condonation of delay in filing assessee, we are not adjudicating upon condonation of delay in filing assessee, we are not adjudicating upon condonation of delay in filing

Shri Balkrishna Vithal Shinde, Mumbai vs. ITO 28(1) (2), Mumbai

ITA 1753/MUM/2021[2011-12]Status: DisposedITAT Mumbai24 Aug 2022AY 2011-12

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am आयकरअपीलसं./ I.T.A. No. 1753/Mum/2021 (ननधधारणवर्ा / Assessment Year: 2011-12) Ito-28(1)(2), Shri Balkrishna Vithal Mumbai-400 703 Shinde A-9, Ganga Tower Co-Op बनाम/ Housing Society, Plot Vs. No. 40A, Sector-16, Vashi, Navi Mumbai -400 703, स्थधयीलेखधसं./जीआइआरसं./ Pan No. Aaips4294A (अपीलधथी/Appellant) (प्रत्यथी / Respondent) : अपीलधथीकीओरसे/ Appellant By : Shri B. N. Rao, Ld. Ar प्रत्यथीकीओरसे/Respondent By : Shri Chetan M. Kacha, Ld. Dr सुनवधईकीतधरीख/ : 03.08.2022 Date Of Hearing घोर्णधकीतधरीख / : 24.08.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 24.02.2020, Passed By Ld. Cit(A)-26

For Appellant: Shri B. N. Rao, Ld. ARFor Respondent: Shri Chetan M. Kacha

Section 144Section 264Section 69ASection 80C

rejecting the application of the assessee. Aggrieved, the assessee then preferred the present appeal against the order of the AO along with condonation for delay. 6.2 In the backdrop of the above facts, it is pertinent to reflect upon the application of Doctrine of Merger in the instant case ... which is in the first appellate authority. Thus, this matter is remanded back to the file of Ld. CIT(A) to consider the condonation of delay which was on account of the fact that assessee was under bonafide belief that matter would be decided in the revision application which

Minal Industries Ltd, Mumbai vs. JCIT (OSD) Cir-10(2)(2), Mumbai

In the result, present appeal by the assessee is dismissed

ITA 597/MUM/2022[2012-13]Status: DisposedITAT Mumbai22 Aug 2022AY 2012-13

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Kiran MehtaFor Respondent: Shri Asif Karmali

Section 249(1)Section 250

present appeal before us is delayed by 46 months. Along with the present appeal, assessee has filed application seeking condonation of delay in filing the appeal, which is also supported by an affidavit sworn by the Managing Director of the assessee company. In the affidavit, the Minal Industries ... impugned order passed by the learned CIT(A) dismissing the manual appeal. In view of the above, the assessee has requested to condone the delay as the same is unintentional and due to circumstances beyond the control of the assessee. On the other hand, learned Departmental Representative („learned

Prakash Industrial Corporation, Mumbai vs. Sandeep Kumar Singh-ITO-19(2)(5), Mumbai

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 524/MUM/2022[10-11]Status: DisposedITAT Mumbai22 Aug 2022

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Ms. Pooja ChhawachhariaFor Respondent: Shri Ajeya Kumar Ojha

Section 143(3)Section 250Section 253(3)

present appeal before us is delayed by 947 days. Along with the present appeal, assessee has filed application seeking condonation of delay in filing the appeal, which is also supported by an affidavit sworn by the Partner of the assessee. In the affidavit, the deponent has submitted as under: Prakash ... immediately paid the appeal fees of the tribunal and got the relevant papers ready. I humbly pray to your honor to condone the delay in filing the appeal for which I shall be grateful to your honor. I always co-operate with the income tax department and once again request

Bhakti Trust, Mumbai-400088 vs. Principal Commissioner of Income Tax, Bangalore

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

ITA 1282/MUM/2022[2022-23]Status: DisposedITAT Mumbai22 Aug 2022AY 2022-23

Bench: Shri Amit Shukla & Shri Amarjit Singh

For Appellant: Shri N.B. GandhiFor Respondent: Dr. Mahesh Akhade

Section 12ASection 12A(1)Section 12A(1)(a)Section 12A(1)(ac)Section 80GSection 80G(5)

grounds before us: “Ground No. 1 a. Your Appellant was prevented from filing the Appeal in time before your honor and prays to condone the delay of 326 days. Ground No. 2 a. The Hon Principal Commissioner of Income Tax / Commissioner erred in passing "order for provisional registration in Form ... attributed the reason for issuing a provisional registration certification because of issuing such certificate by the CPC. Therefore, the assessee has requested that condonation of delay in filing these appeal because of issuing of provisional registration order by the concerned authority without giving any clarification and modification in spite

Mital Vardhibhai Doshi, Mumbai vs. ACIT 19(2), Mumbai

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

ITA 678/MUM/2020[2008-09]Status: DisposedITAT Mumbai18 Aug 2022AY 2008-09

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhmital Vardhibhai Doshi Vs. Acit – 19(2) C/O. Mital Brass, 216, Room No. 207, Shriji Chambers, Matru Mandir, Nana Operahouse,Charaniroad Chowk,Grantroad(W), Mumbai-400004 Mumbai-400007 Pan/Gir No. : Adupd8176D Appellant .. Respondent Appellant By : Shri Himanshi Gandhi.Ar Respondent By : Smt.Mahita Nair.Dr Date Of Hearing 04.08.2022 Date Of Pronouncement 08.08.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals)-5 Passed U/S 143(3) R.W.S 147 & 250. The Revenue Has Raised The Following Revised Grounds Of Appeal:

For Appellant: Shri Himanshi Gandhi.ARFor Respondent: Smt.Mahita Nair.DR

Section 143(1)Section 143(2)Section 143(3)Section 148

claim. 2. The Ld.AR submitted that there is a delay in filling the appeal before the Honble Tribunal and filed an affidavit for condonation of delay and the Ld.DR has no serious objections. Hence the delay is condoned and the appeal is admitted. 3. The brief facts of the case

Amasebail Vyvasaya Seva Sahakari Sangha Limited, Udupi vs. Deputy Commissioner of Income Tax, CPC, Bengaluru

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

ITA 537/BANG/2022[2018-19]Status: DisposedITAT Bangalore18 Aug 2022AY 2018-19

Bench: Shri Chandra Poojariassessment Year: 2018-19

For Appellant: Shri Mahesh R. Uppin, A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel

Section 119Section 139(1)Section 139(4)Section 142(1)Section 143(1)(a)Section 148Section 80ASection 80A(5)Section 80P

perused the materials available on record. In this case, the main plea of the assessee is that assessee filed an application for condonation of delay in filing the income tax return for the assessment year 2018-19 and on this basis, exemption u/s 80P of the Act to be granted ... file of AO to examine whether application filed by the assessee on 30.11.2018 before PCIT, Central Revenue Building, Attavara, Bengaluru for condoning the delay in filing the return of income for the assessment year 2018-19. If it is condoned by the competent authority, the exemption

Shri. Vinod Nevatia, Mumbai vs. Asst CIT 4(2), Mumbai

In the result, appeal by the assessee for assessment year 2013–14

ITA 1392/MUM/2020[2013-14]Status: DisposedITAT Mumbai11 Aug 2022AY 2013-14

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri S.C. TiwariFor Respondent: Ms. Smita Nair, Sr. AR

Section 14ASection 250

appeals filed by the assessee before us are delayed by 411 days. Along with the present appeals, assessee has filed separate application seeking condonation of delay in filing the appeals, which is also supported by an affidavit sworn by the assessee. In the application, the assessee has submitted as under ... Shri Vinod Nevatia ITA No.1391/Mum./2020 ITA No.1392/Mum./2020 10. The appellant sincerely regrets the delay and request the Honourable Members to kindly condone the delay and request your honours to kindly admit the same.” 4. In view of the above, the assessee has requested to condone the delay

Shri. Vinod Nevatia, Mumbai vs. Asst CIT 4(2), Mumbai

In the result, appeal by the assessee for assessment year 2013–14

ITA 1391/MUM/2020[2011-12]Status: DisposedITAT Mumbai11 Aug 2022AY 2011-12

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri S.C. TiwariFor Respondent: Ms. Smita Nair, Sr. AR

Section 14ASection 250

D. Ravilal Resources Management Pvt. Ltd.(Formerly Known As) M/S. Generic Engineering & Construction Pvt. Ltd., Mumbai vs. DCIT 10 (2), Mumbai

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

ITA 469/MUM/2022[2009-10]Status: DisposedITAT Mumbai10 Aug 2022AY 2009-10

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhm/S D Ravilal Resources Vs. Dcit – 10(2) Management Pvt Ltd., Kautilya Bhavan (Formerly Known As M/S. Bkc, Bandra (E) Generic Engineering & Mumbai – 400051. Construction Pvt Ltd) No. A-206, 2Nd Floor, Zest Business Centre, Mg Road, Ghatkopar (E), Mumbai – 400075. Pan/Gir No. : Aaccg2374E Appellant .. Respondent Appellant By : None Respondent By : Smt. Mahita Nair.Dr Date Of Hearing 04.08.2022 Date Of Pronouncement 08.08.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals) – 22, Mumbai Passed U/S 143(3) R.W.S 147 & 250. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: NoneFor Respondent: Smt. Mahita Nair.DR

Section 143(2)Section 143(3)Section 148Section 292B

craves leave to add, alter or amend all or any of above grounds of appeal. 2. The assessee has filed an application for condonation of delay in filling the appeal before the Honble Tribunal and supported by an affidavit. The Ld.DR has no serious objections. We considered the facts ... condoned the delay and the appeal is admitted. 3. The brief facts of the case are that the assessee company is engaged in the business of civil contractor works. The Assessee has filed the return of income for the A.Y 2009-10 on 28.09.2009 disclosing a total income

National Health and Education Society, Mumbai vs. DCIT(Exemption) 2(1), Mumbai

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

ITA 1346/MUM/2022[2013-2014]Status: DisposedITAT Mumbai08 Aug 2022AY 2013-2014

Bench: Shri Amit Shukla, Jm & Shri Amarjit Singh, Am आयकरअपीलसं./ I.T.A. No. 1346/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2013-14) Dcit (Exemp.)-(2)(1), National Health & 6Th Floor, Mtnl Building, Peddar Education Society Road, Mumbai-400 026 P D Hinduja National बिधम/ Hospital & Medical Vs. Research Centre, Veersavarkar Marg, Mumbai-400 016 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaatn0093Q (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : Shri Anil Sathe, Ld. Ar अपीलाथीकीओरसे/ Appellant : By प्रत्यथीकीओरसे/Respondent : Shri Chetan M. Kacha, Ld. Dr By सुनवाईकीतारीख/ : 08.08.2022 Date Of Hearing घोषणाकीतारीख / : 08.08.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 30.03.2022, Passed By National Faceless

For Respondent: Shri Chetan M. Kacha, Ld. DR by

Section 143(3)

appeal only on 14.06.2016 after a delay of 65 days. Against the said delay, the assessee has not taken any ground for condonation of delay in presenting the appeal. It was also observed that the assessee has not made any prayer even after filing the appeal late for condonation

Dy Commissioner of Income Tax, Central Circle-5(3), Mumbai-400021 vs. Board of Examination for Seafares Trust, Navi Mumbai

In the result, the appeal filed by the revenue stands dismissed

ITA 1163/MUM/2022[2017-18]Status: DisposedITAT Mumbai08 Aug 2022AY 2017-18

Bench: Shri Amit Shukla, Jm & Shri Amarjit Singh, Am आयकरअपीलसं./ I.T.A. No. 1163/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2017-18) Board Of Examination Dcit-Cc – 5(3), For Seafarers Trust R. No. 1906, 19Th Floor, Air बिधम/ Plot 94, Imei House, India Building, Nariman Vs. Sector 19, Nerul, Navi Point, Mumbai-400 021 Mumbai-400 706 स्थायीलेखासं./जीआइआरसं./ Pan No. Aabtb1052C (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Chetan M. Kacha, Ld. Dr प्रत्यथीकीओरसे/Respondent By : Shri Karthik Natarajan, Ld. Ar सुनवाईकीतारीख/ : 08.08.2022 Date Of Hearing घोषणाकीतारीख / : 08.08.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Revenue Against The Impugned Order Dated 24.12.2021, Passed By Ld. Cit(A)-53, Mumbai For The Quantum Of Assessment Passed U/S 143(3) For Ay 2017-18. The Revenue Has Taken The Following Grounds Of Appeal:-

For Appellant: Shri Chetan M. KachaFor Respondent: Shri Karthik Natarajan

Section 11(1)Section 11(2)Section 12ASection 143(3)

brought on record that the appeal of revenue is barred by limitation. However, Ld. AO has filed an application for condonation of delay, which are as under:- 2. It has been communicated to this office vide above referred Form dated 08.07.2022 received in this office on 12.07.2022 that the above

M/S. Nath Industries Ltd, Mumbai vs. ACIT, Circle-1(3) (1), Mumbai

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

ITA 832/MUM/2022[2018-19]Status: DisposedITAT Mumbai04 Aug 2022AY 2018-19

For Appellant: Shri N. R. AgarwalFor Respondent: Shri Chetan M. Kacha (Sr. AR)

Section 119Section 139(5)

under receipt no. 859702751211220 in respect of the merged entity; and also filed application before the Ld. CIT City-1 for condonation of delay in filing revised the return on 29.01.2021 and 12.02.2021. It was pointed out by the assessee before AO that the filing of revised return within ... Nath Industries Ltd. Subsequently, on 12.2.2021, it applied before principal commissioner of Income Tax-1 Mumbai for condonation of delay in filling revised return. 4.2 I have gone through the submission of the appellant. In the instant case, the merger of the companies was approved by Hon'ble NCLT

M/S. Rakesh Metal & Tubes, Mumbai vs. Income Tax Officer 19(3) (1), Mumbai

ITA 5/MUM/2022[2009-2010]Status: DisposedITAT Mumbai29 Jul 2022AY 2009-2010

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2009-10

For Appellant: Shri Satyaprakash Singh, A.RFor Respondent: Shri Ashish Kumar, D.R

Section 143(3)Section 147Section 250

quashed. 2. On facts and circumstances of the case and in law. ihe Hon. C.I.T.(Appeals). NFAC, Delhi has erred in non-condoning the delay in presenting the Appellant even though sufficient cause was demonstrated beyond doubt. 3. On facts and circumstances of the case ... months. 5. Now before the Tribunal assessee has challenged the impugned order passed by Ld. CIT(A) primarily on the ground that non condoning the delay by Ld. CIT(A) is arbitrary, illegal and sought to condone the same on the grounds inter alia that the entire income tax related

M/S. Brandmark Solution Pvt Ltd, Mumbai vs. TDS CPC/AO NFAC, Delhi

ITA 2410/MUM/2021[2015-16]Status: DisposedITAT Mumbai29 Jul 2022AY 2015-16

Bench: Shri Baskaran Br & Shri Kuldip Singh

For Appellant: Ms. Neha Anchaliya, A.RFor Respondent: Shri C.T. Mathews, D.R

Section 200ASection 234E

appeals are filed late with the delay of 3 years and six months (approximately) before the Ld. CIT(A) who has declined to condone the delay and dismissed the appeal on grounds of limitation as well as on merits. 7. Assessee moved an application for condonation of delay supported with ... account of any deliberate act. 8. However, on the other hand, the Ld. D.R. for the Revenue opposed the application for condonation of delay on the ground that the late filing of appeals in this case is apparently malafide due to callous attitude of the assessee and prayed for dismissal

M/S. Brandmark Solution Pvt Ltd, Mumbai vs. TDS, CPC/AO Nafc, Delhi

ITA 2409/MUM/2021[2014-15]Status: DisposedITAT Mumbai29 Jul 2022AY 2014-15

Bench: Shri Baskaran Br & Shri Kuldip Singh

For Appellant: Ms. Neha Anchaliya, A.RFor Respondent: Shri C.T. Mathews, D.R

Section 200ASection 234E

Narayan J. Pagarani, Mumbai vs. ACIT 21 (1), Mumbai

In the result, appeals filed by the assessee are allowed

ITA 659/MUM/2019[2004-05]Status: DisposedITAT Mumbai29 Jul 2022AY 2004-05

Bench: Shri Pavan Kumar Gadale, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Rajesh SanghviFor Respondent: Shri S.N. Kabra

Section 142(1)Section 143(1)Section 143(3)Section 44ASection 80H

back in 2011. The new tax consultant advised, that I should now file appeal before Hon'ble ITAT along with petition of condonation of delay explaining the wrong course of action taken by the appellant from 2011 till now, in innocence and in ignorance of the possible complex legal options ... advice on next course of action. The new consultant opined that appeal should be filed before the Tribunal along with petition for condonation of delay in fling of appeal. The assessee summed up his petition for condonation of delay stating that the delay is because of wrong legal advice

Narayan J. Pagarani, Mumbai vs. ACIT - 21 (1), Mumbai

In the result, appeals filed by the assessee are allowed

ITA 658/MUM/2019[2003-04]Status: DisposedITAT Mumbai29 Jul 2022AY 2003-04

Bench: Shri Pavan Kumar Gadale, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Rajesh SanghviFor Respondent: Shri S.N. Kabra

Section 142(1)Section 143(1)Section 143(3)Section 44ASection 80H