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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

Pitamber Wadhwani, Indore vs. DCIT-1(1), Indore

Appeal is allowed for statistical purpose

ITA 513/IND/2025[2017-18]Status: DisposedITAT Indore23 Dec 2025AY 2017-18

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyaniassessment Year:2017-18 Pitamber Wadhwani, Dcit-1(1) 101, Saakaar Kunj, 3 Indore बनाम/ Shanti Nagar, Vs. Indore (Assessee/Appellant) (Revenue/Respondent) Pan: Aacpw6714B Assessee By Shri Sandeep Garg, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 11.12.2025 Date Of Pronouncement 23.12.2025

Section 143(3)Section 154Section 249Section 250Section 253(5)

appeal is delayed by 151 days and therefore time-barred. Ld. AR for assessee submitted that the assessee has filed an application for condonation of delay; the same is scanned and re-produced for an immediate reference: Page 2 of 7 Pitamber Wadhwani ITA No. 513/Ind/2025 ... hearing. 3. It further emerged during hearing that the CIT(A) has dismissed assessee’s first-appeal by passing following order: “Decision on Condonation of Delay: The facts of the case and the grounds raised by the appellant have been considered carefully. It is noticed that there is a delay

Sanjay Mukati, Indore vs. Income Tax Officer-2(1), Main Building Indore

Appeal is allowed for statistical purpose

ITA 510/IND/2025[2012-13]Status: DisposedITAT Indore23 Dec 2025AY 2012-13

Bench: Ms. Suchitra R. Kambleand**

Section 143(3)Section 250Section 253(5)

appeal is delayed by 31 days and therefore time-barred. Ld. AR for assessee submitted that the assessee has filed an application for condonation of delay supported by affidavit; the affidavit filed by assessee is scanned and re-produced for an immediate reference: ![](_page_2_Picture_1.jpeg) I, Sanjay Mukati, S/o Shri Murari ... appeal is therefore due to bona fide reasons and not deliberate or intentional. - 7. That I respectfully request the Hon'ble Tribunal to condone the delay in filing the appeal and admit the same for hearing in the interest of justice. - 8. That the contents of the accompanying condenation petition

Jastej Gorowara, Bhopal vs. Commissioner of Income-Tax (Appeals), Delhi

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

ITA 277/IND/2025[2015-16]Status: DisposedITAT Indore23 Dec 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Ashish Porwal, Sr. DR
Section 133(6)Section 147Section 148Section 271(1)(c)Section 68

277/Ind/2025 Jastej Gorowara vs. CIT(A) A.Ys. 2011-12 & 2015-16 7. We note that the assessee has filed application for condonation of delay of 747 days in filing of the present appeal. As regards the delay of 747 days in filing the present appeal and the non-appearance before ... A.Ys. 2011-12 & 2015-16 v. Mst. Katiji (1987) 167 ITR 471 (SC). On these facts, a prayer was made for condonation of delay and for restoration of the matter to the file of the CIT(Appeals) for fresh adjudication on merits. 8. We have heard the rival contentions

Jastej Gorowara, Bhopal vs. CIT(A), Delhi

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

ITA 276/IND/2025[2011-12]Status: DisposedITAT Indore23 Dec 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Ashish Porwal, Sr. DR
Section 133(6)Section 147Section 148Section 271(1)(c)Section 68

277/Ind/2025 Jastej Gorowara vs. CIT(A) A.Ys. 2011-12 & 2015-16 7. We note that the assessee has filed application for condonation of delay of 747 days in filing of the present appeal. As regards the delay of 747 days in filing the present appeal and the non-appearance before ... A.Ys. 2011-12 & 2015-16 v. Mst. Katiji (1987) 167 ITR 471 (SC). On these facts, a prayer was made for condonation of delay and for restoration of the matter to the file of the CIT(Appeals) for fresh adjudication on merits. 8. We have heard the rival contentions

Shri Shanidev Charitable Trust, Ajmer vs. CIT Exemption, Jaipur

The appeals are hereby dismissed being barred by limitation

ITA 477/JPR/2025[2024-25]Status: HeardITAT Jaipur23 Dec 2025AY 2024-25

Bench: Learned Cit(E), Jaipur By Way Of Two Application I.E. One U/S 12A(1)(Ac)(Iii) Of The Income Tax Act ( In Short “The Act”) To Seek Its Registration. Shri Shanidev Charitable Trust, Ajmer. Another Application Were Also Presented By The Applicant Before Learned Cit(E) Seeking Approval U/S 80G Of The Act.

For Appellant: NoneFor Respondent: Shri Rajesh Ojha, CIT
Section 12A(1)(ac)Section 3Section 5Section 80G

days. 4. In view of the deficiency notes raised by the Registry, the applicant was required to file application, if any, seeking condonation of delay. However, despite opportunities, no such application seeking condonation of delay came to be filed. 5. Both the impugned orders are dated 29.11.2024. As mentioned ... Bench on 13.08.2025, 17.09.2025 and 11.11.2025, but none has appeared on behalf of the applicant, what to say of filing of application seeking condonation of delay. Even today, none has appeared on behalf of the applicant despite wait. In PATHAPATI SUBBA REDDY (DIED) BY L.Rs. & ORS. v. THE SPECIAL DEPUTY

Shri Shanidev Charitable Trust, Ajmer vs. CIT Exemption, Jaipur

The appeals are hereby dismissed being barred by limitation

ITA 476/JPR/2025[2024-25]Status: HeardITAT Jaipur23 Dec 2025AY 2024-25

Bench: Learned Cit(E), Jaipur By Way Of Two Application I.E. One U/S 12A(1)(Ac)(Iii) Of The Income Tax Act ( In Short “The Act”) To Seek Its Registration. Shri Shanidev Charitable Trust, Ajmer. Another Application Were Also Presented By The Applicant Before Learned Cit(E) Seeking Approval U/S 80G Of The Act.

For Appellant: NoneFor Respondent: Shri Rajesh Ojha, CIT
Section 12A(1)(ac)Section 3Section 5Section 80G

days. 4. In view of the deficiency notes raised by the Registry, the applicant was required to file application, if any, seeking condonation of delay. However, despite opportunities, no such application seeking condonation of delay came to be filed. 5. Both the impugned orders are dated 29.11.2024. As mentioned ... Bench on 13.08.2025, 17.09.2025 and 11.11.2025, but none has appeared on behalf of the applicant, what to say of filing of application seeking condonation of delay. Even today, none has appeared on behalf of the applicant despite wait. In PATHAPATI SUBBA REDDY (DIED) BY L.Rs. & ORS. v. THE SPECIAL DEPUTY

Bhikhabhai Ramanbhai Patel, Ahmedabad vs. The ITO, Ward-3(2)(1), Ahmedabad

In the result, the appeal of the assessee stands dismissed

ITA 746/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2017-18

Bench: Shri Sanjay Gargassessment Year : 2017-18 Bhikhabhai Ramanbhai Patel The Ito, C/O. M/S.Bhikhalal Ramanlal Patel Vs Ward-3(2)(1) Nr.Borring, St Road, Sanand Ambawadi Pan:Aehpp 2121 A Ahmedabad. (Applicant) (Responent) : Assessee By Shri S.N. Divatia, Ar Revenue By : Shri Ravindra, Ld.Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 17/12/2025 घोषणा क" तारीख /Date Of Pronouncement: 23/12/2025

For Respondent: Shri Ravindra, ld.SR.DR
Section 250

during the demonetization period. 3. The appeal of the assessee is time barred by 39 days. A separate application has been filed for condonation of delay. Considering the averments made in the application, the delay in filing the appeal before the Tribunal is condoned. 2 4. Brief facts

Swa. Savitribai Bhikalal Agrawal Memorial Trust, Nandurbar vs. Commissioner of Income Tax (Exemption), Pune

In the result, both the appeals filed by the appellant trust are allowed for statistical purposes

ITA 1576/PUN/2025[2023-24]Status: DisposedITAT Pune23 Dec 2025AY 2023-24

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1575 & 1576/Pun/2025 Swa Savitribai Bhikalal Vs. Cit (Exemption), Agrawal Memorial Trust, Pune Nandurbar, Maharashtra – 425426 Pan : Aavts8830R Appellant Respondent

For Appellant: Shri Rahul NaharFor Respondent: Shri Amit Bobde
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)(iii)

delay of 897 days and 904 days respectively in filing the instant appeals before this Tribunal. Appellant has filed an Affidavit for condonation of delay explaining the reasons which led to delay. “1. That I am the duly appointed Authorised Trustee of the above- named Trust and am f competent ... cure the requirement of appellate adjudication. Immediately thereafter, the Trust initiated steps to prepare and file the appeal along with this application for condonation of delay. 4. That the delay in filing the appeal is purely on account of a bonafide misunderstanding of the legal position caused by the incorrect

Swa. Savitribai Bhikalal Agrawal Memorial Trust, Visarwadi, Navapur vs. Commissioner of Income Tax ( Exemption), Pune

In the result, both the appeals filed by the appellant trust are allowed for statistical purposes

ITA 1575/PUN/2025[2023-24]Status: DisposedITAT Pune23 Dec 2025AY 2023-24

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1575 & 1576/Pun/2025 Swa Savitribai Bhikalal Vs. Cit (Exemption), Agrawal Memorial Trust, Pune Nandurbar, Maharashtra – 425426 Pan : Aavts8830R Appellant Respondent

For Appellant: Shri Rahul NaharFor Respondent: Shri Amit Bobde
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)(iii)

delay of 897 days and 904 days respectively in filing the instant appeals before this Tribunal. Appellant has filed an Affidavit for condonation of delay explaining the reasons which led to delay. “1. That I am the duly appointed Authorised Trustee of the above- named Trust and am f competent ... cure the requirement of appellate adjudication. Immediately thereafter, the Trust initiated steps to prepare and file the appeal along with this application for condonation of delay. 4. That the delay in filing the appeal is purely on account of a bonafide misunderstanding of the legal position caused by the incorrect

Lingannagari Parinitha, Hyderabad vs. ITO., Ward-11(4), Hyderabad

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

ITA 990/HYD/2025[2017-18]Status: DisposedITAT Hyderabad23 Dec 2025AY 2017-18

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, Rajnish PissayFor Respondent: Sri Gudimella V P Pavan Kumar, Sr. AR
Section 142(1)Section 144Section 250Section 69A

outset, there is a delay of 276 days in filing the present appeal before the Tribunal. The assessee has filed petition seeking for condonation of delay along with affidavit 2 ITA.No.990/Hyd./2025 explaining the reasons for the delay in filing the appeal within the period of limitation. The learned ... learned Authorised Representative of the Assessee has also filed relevant medical certificates and reports in support of his contention and pleaded for condonation of delay of 276 days in filing the present appeal before the Tribunal. 3. On the other hand, the learned DR strongly opposed for condonation of delay

Arun Kumar Sarup, Mumbai vs. Dy. Commissioner of Income Tax Circle 1(1)(1), Mumbai

In the result, all the three appeals are treated as allowed for statistical purposes

ITA 4709/MUM/2025[2015-2016]Status: DisposedITAT Mumbai23 Dec 2025AY 2015-2016

Bench: Hon’Ble Shri Sandeep Gosain& Shri Prabhash Shankararun Kumar Sarup Vs. Dy. Commissioner Of 2Nd Floor, Amartara Pvt. Ltd. Income Tax Circle Saki Vihar Road, Powai, 1(1)(1), Mumbai Mumbai – 400072. 553, 5Th Floor, Aaykar Bhavn, Maharshi Karve Road, Mumbai - 400020 Pan/Gir No. Aahps2384Q (Applicant) (Respondent)

Section 250Section 271(1)(c)Section 69

details in respect of the same was submitted.” 2. Ground No. 1, This ground raised by the assessee relates to seeking condonation of delay of 91 days in filing the present appeal. In this regard an application for seeking condonation of delay has been separately filed by the assessee, wherein ... which was due to be filed on 20/04/2025, Thus, there is delay of 91 days. 2] I am herewith submitting an affidavit for condonation of delay narrating all the facts. 3] I therefore, in the light of the above mentioned facts submit that the delay is due to the circumstances

Mayur Govindbhai Patel, Mumbai vs. ITO, Ward-24(2)(1), Mumbai

Appeal is dismissed

ITA 4178/MUM/2025[2011-12]Status: DisposedITAT Mumbai23 Dec 2025AY 2011-12

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

For Appellant: Shri Dhaval ShahFor Respondent: Shri Umashankar Prasad
Section 143(3)Section 147Section 263Section 263(1)

Explaining the reasons for delay in filing the present appeal, Learned Authorized Representative for the Assessee took us through the application seeking condonation of delay, the supporting affidavit of the Assessee and confirmation letter issued by the earlier chartered accountant engaged by the Assessee for handling tax matters ... revisions and continued to pursue/participate in the consequent assessment proceedings. It was submitted that the explanation offered by the Assessee for seeking condonation of delay was neither bonafide nor reasonable. On the basis of abovesaid the Learned Departmental Representative submitted that the application seeking condonation of delay for more than

Shantilal Narottamdas Panchal, Malad East vs. ITO-41(3)(4), Mumbai, Bandra Kurla Complex

Appeal is allowed

ITA 3570/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Dec 2025AY 2017-18

Bench: Him.

For Appellant: Shri Ravindra PoojaryFor Respondent: Shri Bhagirath Ramawat
Section 144BSection 147Section 148Section 148ASection 151Section 56(2)(vii)

Assessment Year 2017-2018. Delay of 37 days in filing the present appeal is condoned for the reasons stated in the application seeking condonation of delay accompanied by supporting affidavit in view of the judgment of the Hon’ble Supreme Court in the case of Collector of Land Acquisition

Pinkal Dilip Bhansali, Mumbai vs. Income Tax Officer 19(2)(4), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 1701/MUM/2025[2011-12]Status: DisposedITAT Mumbai23 Dec 2025AY 2011-12

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2011-12

For Appellant: Mr. Sapnesh D Sheth (Virtually
Section 148Section 69C

issue of We have considered the rival submissions on the issue of We have considered the rival submissions on the issue of condonation of delay. In our considered view, the assessee has condonation of delay. In our considered view, the assessee has condonation of delay. In our considered view

Central Council for Research in Ayurvedic Sciences, Delhi vs. Income Tax Officer, Ward 49(1), Delhi

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

ITA 2274/DEL/2025[2012-13]Status: DisposedITAT Delhi23 Dec 2025AY 2012-13

Bench: Shri M Balaganesh & Shri Vimal Kumarassessment Year: 2012-13 Central Council For Research In Vs. Income Tax Officer, Ayurvedic, C/O M K Bhatt & Co., Ward 49 (1), Cas, G-7, Preet Vihar, Delhi New Delhi-1100 92 Pan :Aaaac8367R (Appellant) (Respondent)

Section 144Section 250

Shri Jitender Singh, CIT DR Date of hearing 09.12.2025 Date of pronouncement 23.12.2025 ORDER PER VIMAL KUMAR, JUDICIAL MEMBER: The application for condonation of delay of 378 days in filing appeal and appeal filed assessee are against the order dated 25.01.2024 of Learned Commissioner of Income Tax (Appeals), New Delhi

Kirti Tripathi, Bhopal vs. ITO 2(4), Bhopal

Appeal is allowed for statistical purpose

ITA 572/IND/2025[2011-12]Status: DisposedITAT Indore22 Dec 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri B.M. Biyani

Section 139(1)Section 147Section 148

appeal is delayed by 343 days and therefore time-barred. Ld. AR for assessee submitted that the assessee has filed an application for condonation of delay; the application filed by assessee is scanned and re-produced for an immediate reference: Page 2 of 7 Kirti Tripathi ITA No. 572/Ind/2025

Umesh Kumar Motwani, Indore vs. CIT(A), Indore

Appeal is allowed for statistical purpose

ITA 538/IND/2025[2015-16]Status: DisposedITAT Indore22 Dec 2025AY 2015-16

Bench: Ms. Suchitra R. Kamble & Shri B.M. Biyani

Section 143(2)Section 144

appeal is delayed by 109 days and therefore time-barred. Ld. AR for assessee submitted that the assessee has filed an application for condonation of delay; the same is scanned and re-produced for an immediate reference: Page 2 of 7 Umesh Kumar Motwani ITA No. 538/Ind/2025 ... Commissioner of Income Tax (Appeals), Indore Sub: Application for Condonation of Delay in Filing Appeal — In the case of Shri Umesh Kumar Motwani Respected Sir/Madam, I, Umesh Kumar Motwani, S/o Shri Lokchand Ji, residing at 205, Guru Kripa Blossom, Pagnishpaga, Indore, MP .452001 respectfully submit the following for your kind

Ravindra Jaiswal, Badwani vs. Income Tax Officer, Ward Sendhwa, Sendwa

ITA 431/IND/2025[2017-18]Status: DisposedITAT Indore22 Dec 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri B.M. Biyani

Section 144Section 253(5)

appeal is delayed by 40 days and therefore time-barred. Ld. AR for assessee submitted that the assessee has filed an application for condonation of delay; the same is scanned and re-produced for an immediate reference: Ravindra Jaiswal ITA No. 431/Ind/2025 - AY 2017-18 BEFORE THE HON'BLE INCOME ... APPELLANT TRIBUNAL, INDORE BENCH In the matter of :- RAVINDRA JAISWAL Assessment Year: 2017-18 PAN NO. : - ALIPJ2418E Prayer for condonation of delay Most respectfully the appellant submits as under: - 1. That, the above appeal is being filed against the order of Ld. CIT(A) dated 20.01.2025. 2. That, the said

Shri Motilal Nagar Smriti Shikshan Samiti, Indore vs. CIT Exemption, Bhopal

Appeal is allowed

ITA 384/IND/2025[2020-21]Status: DisposedITAT Indore22 Dec 2025AY 2020-21

Bench: Shri Siddhartha Nautiyal

Section 11Section 11(1)Section 11(2)Section 119Section 139Section 142(1)Section 143(3)Section 263

during assessment-proceeding, after a delay of 365 days, but the assessee did not file any approval granting condonation of delay by Page 2 of 6 Shri Motilal Nagar Smriti Shikshan Samiti ITA No. 384/Ind/2025 - AY 2020-21 CBDT u/s 119 and yet the AO has allowed benefit of accumulation

Sarvhitkari Adhyatmik Kendra, Vpo Dharamgarh, Kharar vs. Commissioner of Income Tax (E), Chandigarh, Chandiagrh

The appeal stand allowed for statistical purposes

ITA 958/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh22 Dec 2025AY 2023-24

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.958/Chandi/2025 Sarvhitkari Adhyatmik Kendra Cit (Exemptions) बनाम/ Vpo Dharamgarh, Kharar Chandigarh - 160017 Vs. Sas Nagar (Punjab) – 140306 "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aayts-2853-F (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ajay Jain (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Smt. Tarundeep Kaur (Cit) – Ld. Dr (Virtual Mode) सुनवाईकीतारीख/Date Of Hearing : 22.12.2025 घोषणाकीतारीख /Date Of Pronouncement 22.12.2025 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee Arises Out Of An Order Of Ld. Commissioner Of Income Tax (Exemptions), Chandigarh [Cit(E)] Dated 26-03-2024 Rejecting Registration Application As Filed By The Assessee Seeking Registration U/S 12A(1)(Ac)(Iii). Upon Perusal Of Para-3 Of The Impugned Order, It Could Be Seen That The Application Has Been Rejected Since The Assessee Filed Only Partial Details As Required Which Led Ld. Cit(E) To Deny The Registration. Aggrieved The Assessee Is In Further Appeal Before Us.

For Appellant: Shri Ajay Jain (CA) – Ld. ARFor Respondent: Smt. Tarundeep Kaur (CIT) – Ld. DR (Virtual Mode)
Section 12A(1)(ac)

assessee-trust. Apparently, the delay has occurred due to lapse on the part of assessee’s counsel. The Ld. AR prayed for condonation of delay and also stated that the assessee is in a position to substantiate its application, in case another opportunity of hearing is granted to the assessee