In the result, the appeal filed by the assessee in ITA No
Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)
condoned the delay in filing the appeal, however not entertained application u/s. 46A of the Rules, since the assessee failed to file the same before the Assessing Officer, thereby rejected the claim of the assessee and upheld the addition made by the Assessing Officer by observing as follows: “…..vi. From the submissions of the appellant assessee this Appellate authority