Bench: The Tribunal Has Caused The Delay Of 87 Days In Filing The Appeal. The Assessee Enclosed The United States Passport Copy Of His Brother, Who Visited India In December 2023. We Are Satisfied With The Reasons Stated In The Notarized Affidavit Thereby We Hereby Condone The Delay Of 87 Days In Filing The Above Appeals & Adjudicate The Cases On Merits.
Section 163 of the Act, the assessee being an Agent in relation to the Non-Residents namely his brother Shri Mahesh Vitthaldas Desai and Smt. Smita Mahesh Desai, the assessee is liable to pay tax, if the owners who sold the property have failed to pay the respective taxes being a Representative Assessee. However neither the owners of the property