In the result, both appeals filed by the assessee are allowed for statistical purposes
Bench: : Shri S. Rifaur Rahman
Section 154 of the Income Tax Act, 1961, and the delay in filing the appeal was neither intentional nor deliberate, but caused by a bona fide belief that the issue would be resolved in rectification proceedings. 3. That the Ld. CIT(A) erred in not condoning the delay despite established judicial principles that substantial justice should prevail over technical considerations