Bench: Shri Vijay Pal Rao & Shri B.M. Biyani
rectification application u/s 154 before the AO but no avail. Thus, it is clear that by filing these appeals belatedly there was no malafide intention to take any undue advantage by assessee. The assessee has acted on the advice of the tax consultant for not filing the appeal within the period of limitation and therefore, in the facts and circumstances