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88 results for “TDS”+ Condonation of Delayclear

Sorted by relevance

Patna615Chennai388Mumbai315Delhi280Pune237Raipur209Nagpur187Hyderabad172Kolkata156Chandigarh140Bangalore132Jaipur124Ahmedabad88Cuttack68Cochin68Visakhapatnam50Lucknow47Surat44Indore37Rajkot32Dehradun23Amritsar20Panaji16Jodhpur11Guwahati10Ranchi7Jabalpur7Agra7Allahabad5Varanasi5

Key Topics

TDS55Addition to Income46Section 25034Section 143(3)33Section 1033Section 143(1)31Deduction29Disallowance27Section 14825Section 147

RADHE FINSEC INDIA LTD.,AHMEDABAD vs. THE ITO, WARD-3(1)(2), AHMEDABAD

In the result, the appeal filed by the Assessee allowed for statistical purpose

ITA 506/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad06 Jun 2025AY 2013-14

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T. R. Senthil Kumar (Judicial Member)

Section 115JSection 143(1)Section 234A

condone the delay of 2490 days in filing the above appeal arising out of the intimation passed under section 143(1) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2013-14. I.T.A No. 506/Ahd/2025 A.Y. 2013-14 Page No 2 Radhe Finsec India Ltd. vs. ITO 2. Brief facts

CAT COSMETICS AND HEALTHCARE PVT. LTD.,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD 1(1)(3), AHMEDABAD

In the result, the appeal filed by the Assessee is allowed for statistical purpose

Showing 1–20 of 88 · Page 1 of 5

24
Penalty23
Natural Justice22
ITA 1189/AHD/2024[2012-13]Status: Disposed
ITAT Ahmedabad
21 May 2025
AY 2012-13

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 144Section 40

TDS. In view of the same, such disallowance is prayed to be deleted. 4. The Ld. CIT(A) has erred in law and on facts by disallowing the brought forward loss of Rs. 5,35,488/-. It is submitted that the appeal in the appellant company's case for AY 2011-12 has not yet been decided and is pending

BHIKHABHAI SOMABHAI PATEL,SABARKANTHA vs. THE ITO, WARD-1, HIMATNAGAR

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

ITA 2596/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2018-19
For Appellant: Shri S. N. Divatia & Shri Samir VoraFor Respondent: Shri Rajkumar M Vasavda, Sr. DR
Section 144Section 270ASection 57

delay be condoned and the assessee be given a fair chance to argue his case on merits. ITA Nos.2596 & 2597/Ahd/2025 [Bhikhabhai Somabhai Pate vs. ITO] A.Y. 2018-19 - 3 – 5. We have gone through the orders of the authorities below. The orders reveal the assessee’s case to have been reopened for assessment, finding the assessee to have received interest

BHIKHABHAI SOMABHAI PATEL,SABARKANTHA vs. THE ITO, WARD-1,, HIMATNAGAR

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

ITA 2597/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2018-19
For Appellant: Shri S. N. Divatia & Shri Samir VoraFor Respondent: Shri Rajkumar M Vasavda, Sr. DR
Section 144Section 270ASection 57

delay be condoned and the assessee be given a fair chance to argue his case on merits. ITA Nos.2596 & 2597/Ahd/2025 [Bhikhabhai Somabhai Pate vs. ITO] A.Y. 2018-19 - 3 – 5. We have gone through the orders of the authorities below. The orders reveal the assessee’s case to have been reopened for assessment, finding the assessee to have received interest

MANSHA TEXTILES PVT. LTD.,VADODARA vs. THE ITO, WARD-2(1)(1), VADODARA

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

ITA 1396/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad13 Oct 2025AY 2012-13

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2012-13 Mansha Textiles P. Ltd. The Ito, Ward-2(1)(1) 1, Vikram Society Vadodara. Gotri Road, Vadodara Pan : Aadcm 0191 J (Applicant) (Responent) Assessee By : Ms.Urvashi Shodhan, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 09/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 13/10/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Ms.Urvashi Shodhan, ARFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 24

delay of about 1012 days. The assessee’s case on condonation was that serious internal disputes between existing and former directors were pending before the Ministry of Corporate Affairs and the Company Law Board, that efforts at amicable resolution failed, and that only the present management later decided to pursue pending legal matters including the present appeal

BALARAM CONSTRUCTION LIMITED,BANASKANTHA vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, appeal filed by the assessee is dismissed as non- maintainable

ITA 727/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad31 Jan 2025AY 2018-19

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2018-19 Balaram Construction Ltd. The Pcit 309, 3Rd Floor, Shital-9 Vs Ahmedabad-1 Opp. Bihari Bagh, Palanpur Ahmedabad – 380 015 Banaskantha – 385 001 (Gujarat) (Gujarat) Pan: Aaacb 6264 C

For Appellant: Shri P.F. Jain, CAFor Respondent: Shri Prathvi Raj Meena, CIT-DR
Section 143(3)Section 263

condonation of delay it is to be ensured that a meritorious case is not thrown out on the grounds of limitation. 4.1. Taking note of this submission of the Ld.Counsel for the assessee, he was asked at bar to explain how on merits he had a good case before the Ld.PCIT such that if the appeal is held

AMISH UMESH JANI,THANE, MAHARASHTRA vs. INCOME TAX OFFICER WARD 4(2)(5), AHMEDABAD, GUJARAT

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

ITA 864/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad24 Jun 2024AY 2010-11

Bench: Shri Ramit Kochar (Accountant Member)

For Appellant: Shri Malay Kalavadia, A.RFor Respondent: Shri M. Anand Kumar, Sr. D.R
Section 142(1)Section 144Section 148Section 271

condoning the delay. So far as other additions of Rs. 3,95,595/-, the assessee has submitted that this is rental income received from Landmark Education Breakthrough Technologies Pvt. Ltd. on which TDS

ISPATAM METALS,AHMEDABAD vs. THE ITO, WAD-5(3)(1), AHMEDABAD

In the result all the grounds raised on merits of the addition made are dismissed

ITA 292/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2018-19

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaassessment Year: 2018-19

For Appellant: Shri S.N. DivetiaFor Respondent: Shri Rignesh Das, CIT-D.R
Section 250

delay in filing of present appeal of 69 days is condoned. 4. Taking up the appeal for adjudication the grounds raised read as under:- “1.1 The order passed by U/s. 250 passed on 09.09.2024 for AY 2018-19 by NFAC, [CIT(A)], Delhi (for short CIT(A)" upholding the additions aggregating to Rs. 4,78,45,243/- made

NIRAJ PRATAPBHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-3(3)(2), (FORMERLY ITO, WARD-3(3)(3),, AHMEDABAD

In the result, the appeal of the assessee in ITA No

ITA 85/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad09 Jul 2024AY 2013-14

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench

For Appellant: Shri Kushal Fofaria, A.RFor Respondent: Smt. Trupti Patel, Sr. D.R
Section 132Section 139Section 143(1)Section 147Section 234ASection 250Section 271(1)(c)Section 68

TDS credit of Rs. 42,830/- while calculating demand of Rs. 2,32,474/-. 6. The learned CIT(A) has erred in law and on facts of the case in confirming action of the learned AO in levying interest u/s. 234A/B/C/D of the Act. 7. The Ld. CIT(A) has erred in law and on facts of the case

NIRAJ PRATAPBHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(2)(FORMERLY ITO, WARD-3(3)(3)), AHMEDABAD

In the result, the appeal of the assessee in ITA No

ITA 87/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad09 Jul 2024AY 2013-14

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench

For Appellant: Shri Kushal Fofaria, A.RFor Respondent: Smt. Trupti Patel, Sr. D.R
Section 132Section 139Section 143(1)Section 147Section 234ASection 250Section 271(1)(c)Section 68

TDS credit of Rs. 42,830/- while calculating demand of Rs. 2,32,474/-. 6. The learned CIT(A) has erred in law and on facts of the case in confirming action of the learned AO in levying interest u/s. 234A/B/C/D of the Act. 7. The Ld. CIT(A) has erred in law and on facts of the case

LAXMANJI KHODAJI SOLANKI (THAKOR),GANDHINAGAR vs. THE ITO, WARD-1, GANDHINAGAR

In the result, appeal of the assessee is allowed for statistical\npurposes

ITA 1626/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad28 Aug 2025AY 2017-18
For Appellant: \nShri Parin Shah, A.RFor Respondent: \nSmt. Kakoli Uttam Ghosh, Sr. DR
Section 115BSection 144Section 148Section 234ASection 249(4)Section 249(4)(b)Section 250Section 271ASection 271FSection 69

condonation of delay.\n\n7. Having heard the contention of both the parties, we find that\nthe assessee has adduced sufficient cause for the delay of 198 days\nin filing of the present appeal before us. We have noted from the\ncontents of Form No.35, which is the form in which the appeal is\nfiled

ATUL LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is partly allowed

ITA 38/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad08 May 2025AY 2017-18

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

For Appellant: Shri Bandish Soparkar, AR
Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 35Section 40Section 9(1)(vii)Section 92C

delay of 86 days is condoned, and the appeal is admitted for adjudication on merits. Brief Facts of the Case 4. The assessee company, Atul Ltd., is engaged in the business of manufacturing dyes, specialty chemicals, agrochemicals, bulk drugs, commodity chemicals, and power generation. For AY 2017–18, the assessee filed its return of income on 29.11.2017 declaring total income

BHAVESH K SHAH,AKOTA vs. INCOME TAX OFFICER WARD 1(2)(1), ALKAPURI

In the result, the appeal of the assessee is allowed

ITA 1188/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad25 Aug 2025AY 2014-15

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Manish J Shah & Shri Rushin Patel, ARsFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR
Section 142(1)Section 148Section 249Section 249(3)Section 44A

condone the delay 'in filling of appeal the delay was inadvertent and unawareness circumstances. 1 hereby requested to provide a genuine ground of natural justice to heard my sight prior to finalize and penalized for unearned income. 2. The honorable commissioner has erred and upheld the ground of settlement of liability in future is not an income

URMILABEN H DAVE DISC FAMILY TRUST,AHMEDABAD vs. THE ITO, WARD-3(3)(5), AHMEDABAD

In the result, all the three appeals of the assessee are partly allowed for statistical purpose

ITA 326/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad30 May 2025AY 2020-21

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 326, 327 & 328/Ahd/2025 A.Y. 2020-21, 2021-22 & 2022-23

For Appellant: Shri Himanshu Shah, A.RFor Respondent: Shri Ravindra, Sr. D.R
Section 143(1)Section 154

condone alleged delay. It is submitted that appeal was filed in time. Appeal was filed on 29/05/2024 against rejection of our grievance on 23/04/2024 and received by us on 30/04/2024. 3. In law and in facts and circumstances of the Appellant's case, the learned Commissioner of Income Tax (Appeals) has grossly erred in not granting credit of TDS

URMILABEN H DAVE DISC FAMILY TRUST,AHMEDABAD vs. THE ITO, WARD-3(3)(5), AHMEDABAD

In the result, all the three appeals of the assessee are partly allowed for statistical purpose

ITA 327/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad30 May 2025AY 2021-22

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 326, 327 & 328/Ahd/2025 A.Y. 2020-21, 2021-22 & 2022-23

For Appellant: Shri Himanshu Shah, A.RFor Respondent: Shri Ravindra, Sr. D.R
Section 143(1)Section 154

condone alleged delay. It is submitted that appeal was filed in time. Appeal was filed on 29/05/2024 against rejection of our grievance on 23/04/2024 and received by us on 30/04/2024. 3. In law and in facts and circumstances of the Appellant's case, the learned Commissioner of Income Tax (Appeals) has grossly erred in not granting credit of TDS

SHREENATHJI ASSOCIATES ,VADODARA vs. THE ITO, WARD-1(2)(4), VADODARA

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

ITA 592/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad04 Dec 2024AY 2013-14

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.592, 593 & 594/Ahd/2024 िनधा"रण वष" /Assessment Years : 2013-14, 2014-15 & 2014-15 Respectively Shreenathji Associates The Ito बनाम/ Sb-1, Shreeji Avenue, W#Ard-1(2)(4) V/S. 11, Sampatrao Colony Vadodara – 390 007 Jetalpur Road Vadodara – 390 007 "थायी लेखा सं./Pan: Abufs 4107 P (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 02/12/2024 घोषणा की तारीख /Date Of Pronouncement: 04/12/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: These Appeals Filed By The Assessee Arise From The Orders Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”], Dated 11/05/2023, 30/11/2023 & 02/02/2024 Respectively For The Assessment Years 2013-14 & 2014-15 (Both Under Original & Reassessment Proceedings). Since The Issue Involved In All These Appeals Is Common, They Are Being Disposed Of By This Common Order For The Sake Of Convenience.

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 143(2)Section 143(3)Section 250Section 43C

TDS from the brokerage payment but had also deposited the same in government account and had filed sufficient evidences in support of the genuineness of the payments made. That apart, the payment made being through banking channel, it could not have been disbelieved merely on some statements extracted from the parties, more ITA Nos.592, 593 & 594/Ahd/2024 Shreenathji Associates

SHREENATHJI ASSOCIATES,VADODARA vs. THE ITO, WARD-1(2)(4), VADODARA

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

ITA 594/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad04 Dec 2024AY 2014-15

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.592, 593 & 594/Ahd/2024 िनधा"रण वष" /Assessment Years : 2013-14, 2014-15 & 2014-15 Respectively Shreenathji Associates The Ito बनाम/ Sb-1, Shreeji Avenue, W#Ard-1(2)(4) V/S. 11, Sampatrao Colony Vadodara – 390 007 Jetalpur Road Vadodara – 390 007 "थायी लेखा सं./Pan: Abufs 4107 P (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 02/12/2024 घोषणा की तारीख /Date Of Pronouncement: 04/12/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: These Appeals Filed By The Assessee Arise From The Orders Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”], Dated 11/05/2023, 30/11/2023 & 02/02/2024 Respectively For The Assessment Years 2013-14 & 2014-15 (Both Under Original & Reassessment Proceedings). Since The Issue Involved In All These Appeals Is Common, They Are Being Disposed Of By This Common Order For The Sake Of Convenience.

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 143(2)Section 143(3)Section 250Section 43C

TDS from the brokerage payment but had also deposited the same in government account and had filed sufficient evidences in support of the genuineness of the payments made. That apart, the payment made being through banking channel, it could not have been disbelieved merely on some statements extracted from the parties, more ITA Nos.592, 593 & 594/Ahd/2024 Shreenathji Associates

SHREENATHJI ASSOCIATES,VADODARA vs. THE ITO, WARD-1(2)(4), VADODARA

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

ITA 593/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad04 Dec 2024AY 2014-15

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.592, 593 & 594/Ahd/2024 िनधा"रण वष" /Assessment Years : 2013-14, 2014-15 & 2014-15 Respectively Shreenathji Associates The Ito बनाम/ Sb-1, Shreeji Avenue, W#Ard-1(2)(4) V/S. 11, Sampatrao Colony Vadodara – 390 007 Jetalpur Road Vadodara – 390 007 "थायी लेखा सं./Pan: Abufs 4107 P (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 02/12/2024 घोषणा की तारीख /Date Of Pronouncement: 04/12/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: These Appeals Filed By The Assessee Arise From The Orders Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”] Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”], Dated 11/05/2023, 30/11/2023 & 02/02/2024 Respectively For The Assessment Years 2013-14 & 2014-15 (Both Under Original & Reassessment Proceedings). Since The Issue Involved In All These Appeals Is Common, They Are Being Disposed Of By This Common Order For The Sake Of Convenience.

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 143(2)Section 143(3)Section 250Section 43C

TDS from the brokerage payment but had also deposited the same in government account and had filed sufficient evidences in support of the genuineness of the payments made. That apart, the payment made being through banking channel, it could not have been disbelieved merely on some statements extracted from the parties, more ITA Nos.592, 593 & 594/Ahd/2024 Shreenathji Associates

DARSHIT GUNWANTBHAI SHAH,AHMEDABAD vs. THE ITO, WARD-1(2)(1), AHMEDABAD

In the result, the appeal is allowed for statistical purposes

ITA 571/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad29 Jul 2025AY 2021-22

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2021-22 Darshit Gunantbhai Shah Ito, Ward-1(2)(1) B/2/236, Madhuvrund Society Vs. Ahmedabad. Ghatlodia Ahmedabad 380 061. Pan : Awmps 9760 R (Applicant) (Responent) : Shri Hardik Vora, Advocate Assessee By : Shri Umesh Kumar Agrawal, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 24/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 29/07/2025 आदेश/O R D E R आदेश आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”] Dated 25.01.2023 For The Assessment Year 2021– 22, Wherein The Disallowance Of Rs.4,67,802/- Made Under Section 43B Of The Act By The Was Confirmed.

For Appellant: Shri Umesh Kumar Agrawal, Sr.DR
Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 250Section 43B

delay of 717 days in filing the appeal is condoned and the appeal is admitted for adjudication on merits. 3. Facts of the Case 3.1 The assessee filed his return of income for A.Y. 2021–22 on 12.03.2022 declaring total income of Rs.7,17,240/-. The return was 3 processed under section 143(1) of the Act by the Centralized

RAVI PLANT BIOTECHNOLOGIES LTD.,VADODARA vs. THE ADDL. CIT, TDS, VADODARA

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

ITA 1199/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad26 Sept 2024AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2016-17

Section 133ASection 201Section 201(1)Section 271C

delay should be condoned before the CIT(A) and since the assessee Company deposited due TDS alongwith interest and late