In the result, appeal of the assessee is allowed for statistical
Bench: : Shri Ramit Kocharassessment Year: 2015-16
section 164(1) of the Act, but the CPC applied MMR and raised demand against the assessee. It was submitted that there was delay of 2176 days in filing appeal before the ld. CIT(Appeals) beyond the time prescribed u/s 249(2), as the assessee was not having knowledge of the intimation/order of the CPC dated 19.10.2017 raising demand against