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35 results for “condonation of delay”+ Section 194Cclear

Sorted by relevance

Kolkata51Mumbai48Chennai46Delhi36Jaipur35Karnataka22Indore15Bangalore13Pune12Raipur11Hyderabad11Ahmedabad8Lucknow8Patna6Rajkot5Cochin4Cuttack4Chandigarh3Amritsar3Ranchi2Varanasi2Visakhapatnam2Surat2Jodhpur1Panaji1Jabalpur1

Key Topics

Section 271C66Section 20163Section 201(1)54TDS30Section 194C28Condonation of Delay26Addition to Income21Penalty17Section 12A6Deduction

INCOME TAX OFFICER (TDS), AJMER vs. DIVISIONL FOREST OFFICER, AJMER

In the result, the appeal of the revenue in ITA no

ITA 359/JPR/2023[2017-18]Status: DisposedITAT Jaipur08 Nov 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 358 to 360/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17 to 2018-19 Income Tax Officer (TDS), Ajmer cuke Vs. Divisional Forest Officer Ajmer LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No. JDHD 02557 C vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Sunil Porwal (CA) jktLo dh vksj ls@ Revenue by : Sh. Anup Singh (Addl. CIT) lquokbZ dh rkjh[k@ Date of Hearing :

For Appellant: Sh. Sunil Porwal (CA)For Respondent: Sh. Anup Singh (Addl. CIT)
Section 10Section 10(20)Section 10(46)Section 11Section 133Section 194CSection 201Section 201(1)

Showing 1–20 of 35 · Page 1 of 2

6
Section 133A5
Section 1445
Section 80P

condone the delay. Income Tax Officer (TDS) vs. Divisional Forest Officer 3. Admitting the appeal of the revenue moving further on merits, the ld. DR submitted that the matter pertaining to Divisional Forest Officer, Ajmer in ITA no. 358/JP/2023 may be taken as a lead case for discussions as the issues involved in the lead case are common and inextricably

ITO(TDS), AJMER vs. DIVISIONL FOREST OFFICER, AJMER

In the result, the appeal of the revenue in ITA no

ITA 360/JPR/2023[2018-19]Status: DisposedITAT Jaipur08 Nov 2023AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 358 to 360/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17 to 2018-19 Income Tax Officer (TDS), Ajmer cuke Vs. Divisional Forest Officer Ajmer LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No. JDHD 02557 C vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Sunil Porwal (CA) jktLo dh vksj ls@ Revenue by : Sh. Anup Singh (Addl. CIT) lquokbZ dh rkjh[k@ Date of Hearing :

For Appellant: Sh. Sunil Porwal (CA)For Respondent: Sh. Anup Singh (Addl. CIT)
Section 10Section 10(20)Section 10(46)Section 11Section 133Section 194CSection 201Section 201(1)Section 80P

condone the delay. Income Tax Officer (TDS) vs. Divisional Forest Officer 3. Admitting the appeal of the revenue moving further on merits, the ld. DR submitted that the matter pertaining to Divisional Forest Officer, Ajmer in ITA no. 358/JP/2023 may be taken as a lead case for discussions as the issues involved in the lead case are common and inextricably

INCOME TAX OFFICER (TDS), AJMER vs. DIVISIONL FOREST OFFICER, AJMER

In the result, the appeal of the revenue in ITA no

ITA 358/JPR/2023[2016-17]Status: DisposedITAT Jaipur08 Nov 2023AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 358 to 360/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17 to 2018-19 Income Tax Officer (TDS), Ajmer cuke Vs. Divisional Forest Officer Ajmer LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No. JDHD 02557 C vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Sunil Porwal (CA) jktLo dh vksj ls@ Revenue by : Sh. Anup Singh (Addl. CIT) lquokbZ dh rkjh[k@ Date of Hearing :

For Appellant: Sh. Sunil Porwal (CA)For Respondent: Sh. Anup Singh (Addl. CIT)
Section 10Section 10(20)Section 10(46)Section 11Section 133Section 194CSection 201Section 201(1)Section 80P

condone the delay. Income Tax Officer (TDS) vs. Divisional Forest Officer 3. Admitting the appeal of the revenue moving further on merits, the ld. DR submitted that the matter pertaining to Divisional Forest Officer, Ajmer in ITA no. 358/JP/2023 may be taken as a lead case for discussions as the issues involved in the lead case are common and inextricably

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, ALWAR, ALWAR vs. ALWAR ZILA DUGDH UTPADAK SAHAKARI SANGH LTD., ALWAR

In the result, the Cross objection of the assessee is allowed for statistical purpose and the Revenue’s appeal is dismissed

ITA 634/JPR/2023[2018-19]Status: DisposedITAT Jaipur27 Jan 2025AY 2018-19

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shr. Anup Singh, Addl.CIT-Sr.DR a
Section 133ASection 143(3)Section 194CSection 201Section 201(1)Section 40Section 80P(2)(d)

delay. The same is condoned and appeal is admitted. Ground No. 1 "The Ld AO has erred on facts and in law in holding that the assessee has defaulted in non-deduction of TDS u/s 194C on payment made for purchase of packing material and disallowances was made ignoring the facts that some direct purchases were made without contract

DY.CONSERVATOR OF FOREST DAUSA,DAUSA vs. INCOME TAX OFFICER TDS, ALWAR

In the results appeal of the

ITA 187/JPR/2023[2015-16]Status: DisposedITAT Jaipur10 May 2023AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh Sunil Kumar UppaddhayFor Respondent: Sh. James Kurian, (CIT) &
Section 201Section 201(1)Section 271C

delay of 304 days in bringing this appeal is condoned and the appeal is hereby admitted for adjudication on merits. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in 180/JPR/2023 & 185/JPR/2023 on the following grounds; Grounds of ITA 180/JPR/2023 Dy. Conservator of Forest Dausa

DY.CONSERVATOR OF FOREST DAUSA,DAUSA vs. INCOME TAX OFFICER TDS, ALWAR

In the results appeal of the

ITA 188/JPR/2023[2016-17]Status: DisposedITAT Jaipur10 May 2023AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh Sunil Kumar UppaddhayFor Respondent: Sh. James Kurian, (CIT) &
Section 201Section 201(1)Section 271C

delay of 304 days in bringing this appeal is condoned and the appeal is hereby admitted for adjudication on merits. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in 180/JPR/2023 & 185/JPR/2023 on the following grounds; Grounds of ITA 180/JPR/2023 Dy. Conservator of Forest Dausa

DY.CONSERVATOR OF FOREST DAUSA,DAUSA vs. INCOME TAX OFFICER TDSINCOME TAX OFFICER TDS, ALWAR

In the results appeal of the

ITA 189/JPR/2023[2017-18]Status: DisposedITAT Jaipur10 May 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh Sunil Kumar UppaddhayFor Respondent: Sh. James Kurian, (CIT) &
Section 201Section 201(1)Section 271C

delay of 304 days in bringing this appeal is condoned and the appeal is hereby admitted for adjudication on merits. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in 180/JPR/2023 & 185/JPR/2023 on the following grounds; Grounds of ITA 180/JPR/2023 Dy. Conservator of Forest Dausa

DY.CONSERVATOR OF FOREST DAUSA,DAUSA vs. INCOME TAX OFFICER TDS, ALWAR

In the results appeal of the

ITA 179/JPR/2023[2011-12]Status: DisposedITAT Jaipur10 May 2023AY 2011-12

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh Sunil Kumar UppaddhayFor Respondent: Sh. James Kurian, (CIT) &
Section 201Section 201(1)Section 271C

delay of 304 days in bringing this appeal is condoned and the appeal is hereby admitted for adjudication on merits. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in 180/JPR/2023 & 185/JPR/2023 on the following grounds; Grounds of ITA 180/JPR/2023 Dy. Conservator of Forest Dausa

DY.CONSERVATOR OF FOREST DAUSA,DAUSA vs. INCOME TAX OFFICER TDS, ALWAR

In the results appeal of the

ITA 180/JPR/2023[2013-14]Status: DisposedITAT Jaipur10 May 2023AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh Sunil Kumar UppaddhayFor Respondent: Sh. James Kurian, (CIT) &
Section 201Section 201(1)Section 271C

delay of 304 days in bringing this appeal is condoned and the appeal is hereby admitted for adjudication on merits. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in 180/JPR/2023 & 185/JPR/2023 on the following grounds; Grounds of ITA 180/JPR/2023 Dy. Conservator of Forest Dausa

DY.CONSERVATOR OF FOREST DAUSA,DAUSA vs. INCOME TAX OFFICER TDS, ALWAR

In the results appeal of the

ITA 181/JPR/2023[2014-15]Status: DisposedITAT Jaipur10 May 2023AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh Sunil Kumar UppaddhayFor Respondent: Sh. James Kurian, (CIT) &
Section 201Section 201(1)Section 271C

delay of 304 days in bringing this appeal is condoned and the appeal is hereby admitted for adjudication on merits. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in 180/JPR/2023 & 185/JPR/2023 on the following grounds; Grounds of ITA 180/JPR/2023 Dy. Conservator of Forest Dausa

DY.CONSERVATOR OF FOREST DAUSADY.CONSERVATOR OF FOREST DAUSA,DAUSA vs. INCOME TAX OFFICER TDSINCOME TAX OFFICER TDS, ALWAR

In the results appeal of the

ITA 183/JPR/2023[2016-17]Status: DisposedITAT Jaipur10 May 2023AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh Sunil Kumar UppaddhayFor Respondent: Sh. James Kurian, (CIT) &
Section 201Section 201(1)Section 271C

delay of 304 days in bringing this appeal is condoned and the appeal is hereby admitted for adjudication on merits. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in 180/JPR/2023 & 185/JPR/2023 on the following grounds; Grounds of ITA 180/JPR/2023 Dy. Conservator of Forest Dausa

DY.CONSERVATOR OF FOREST DAUSA,DAUSA vs. INCOME TAX OFFICER TDS, ALWAR

In the results appeal of the

ITA 182/JPR/2023[2015-16]Status: DisposedITAT Jaipur10 May 2023AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh Sunil Kumar UppaddhayFor Respondent: Sh. James Kurian, (CIT) &
Section 201Section 201(1)Section 271C

delay of 304 days in bringing this appeal is condoned and the appeal is hereby admitted for adjudication on merits. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in 180/JPR/2023 & 185/JPR/2023 on the following grounds; Grounds of ITA 180/JPR/2023 Dy. Conservator of Forest Dausa

DY.CONSERVATOR OF FOREST DAUSA,DAUSA vs. INCOME TAX OFFICER TDS, ALWAR

In the results appeal of the

ITA 184/JPR/2023[2017-18]Status: DisposedITAT Jaipur10 May 2023AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh Sunil Kumar UppaddhayFor Respondent: Sh. James Kurian, (CIT) &
Section 201Section 201(1)Section 271C

delay of 304 days in bringing this appeal is condoned and the appeal is hereby admitted for adjudication on merits. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in 180/JPR/2023 & 185/JPR/2023 on the following grounds; Grounds of ITA 180/JPR/2023 Dy. Conservator of Forest Dausa

DY.CONSERVATOR OF FOREST DAUSA,DAUSA vs. INCOME TAX OFFICER TDS, ALWAR

In the results appeal of the

ITA 185/JPR/2023[2013-14]Status: DisposedITAT Jaipur10 May 2023AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh Sunil Kumar UppaddhayFor Respondent: Sh. James Kurian, (CIT) &
Section 201Section 201(1)Section 271C

delay of 304 days in bringing this appeal is condoned and the appeal is hereby admitted for adjudication on merits. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in 180/JPR/2023 & 185/JPR/2023 on the following grounds; Grounds of ITA 180/JPR/2023 Dy. Conservator of Forest Dausa

DY.CONSERVATOR OF FOREST DAUSA,DAUSA vs. INCOME TAX OFFICER TDS, ALWAR

In the results appeal of the

ITA 186/JPR/2023[2014-15]Status: DisposedITAT Jaipur10 May 2023AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh Sunil Kumar UppaddhayFor Respondent: Sh. James Kurian, (CIT) &
Section 201Section 201(1)Section 271C

delay of 304 days in bringing this appeal is condoned and the appeal is hereby admitted for adjudication on merits. 5. Before moving towards the facts of the case we would like to mention that the assessee has assailed the appeal in 180/JPR/2023 & 185/JPR/2023 on the following grounds; Grounds of ITA 180/JPR/2023 Dy. Conservator of Forest Dausa

CONSERVATOR OF FOREST AND FIELD DIRECTOR TIGER PROJECT SARISKA,SARISKA ALWAR vs. INCOME TAX OFFICER WARD TDS , MOTI DUNGARI ALWAR

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

ITA 473/JPR/2023[2013-14]Status: DisposedITAT Jaipur08 Nov 2023AY 2013-14

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

delay of 232 days in filing the present appeal by the assessee is condoned in view of the decision of Hon’ble Conservator of Forest and Field Tiger Project Sariska vs. ITO(TDS) Supreme Court in the case of Collector, land Acquisition vs. Mst. Katiji and Others, 167 ITR 471 (SC) as the assessee is prevented by sufficient cause

CONSERVATOR OF FOREST AND FIELD DIRECTOR TIGER PROJECT SARISKA,SARISKA ALWAR vs. INCOME TAX OFFICER WARD TDS , MOTI DUNGARI ALWAR

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

ITA 475/JPR/2023[2015-16]Status: DisposedITAT Jaipur08 Nov 2023AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

delay of 232 days in filing the present appeal by the assessee is condoned in view of the decision of Hon’ble Conservator of Forest and Field Tiger Project Sariska vs. ITO(TDS) Supreme Court in the case of Collector, land Acquisition vs. Mst. Katiji and Others, 167 ITR 471 (SC) as the assessee is prevented by sufficient cause

CONSERVATOR OF FOREST AND FIELD DIRECTOR TIGER PROJECT SARISKA ,SARISKA ALWAR vs. INCOME TAX OFFICER WARD TDS, ALWAR

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

ITA 466/JPR/2023[2009-10]Status: DisposedITAT Jaipur08 Nov 2023AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

delay of 232 days in filing the present appeal by the assessee is condoned in view of the decision of Hon’ble Conservator of Forest and Field Tiger Project Sariska vs. ITO(TDS) Supreme Court in the case of Collector, land Acquisition vs. Mst. Katiji and Others, 167 ITR 471 (SC) as the assessee is prevented by sufficient cause

CONSERVATOR OF FOREST AND FIELD DIRECTOR TIGER PROJECT SARISKA,SARISKA ALWAR vs. INCOME TAX OFFICER WARD TDS, ALWAR

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

ITA 470/JPR/2023[2010-11]Status: DisposedITAT Jaipur08 Nov 2023AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

delay of 232 days in filing the present appeal by the assessee is condoned in view of the decision of Hon’ble Conservator of Forest and Field Tiger Project Sariska vs. ITO(TDS) Supreme Court in the case of Collector, land Acquisition vs. Mst. Katiji and Others, 167 ITR 471 (SC) as the assessee is prevented by sufficient cause

CONSERVATOR OF FOREST AND FIELD DIRECTOR TIGER PROJECT SARISKA,SARISKA ALWAR vs. INCOME TAX OFFICER WARD TDS, MOTI DUNGARI ALWAR

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

ITA 471/JPR/2023[2011-12]Status: DisposedITAT Jaipur08 Nov 2023AY 2011-12

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 450, 466, 470 to 475/JP/2023 fu/kZkj.k o"kZ@Assessment Years : 2016-17, 2009-10, 2010-11 to 2015-16 M/s Conservator of Forest and Field Tiger Project Sariska, Alwar cuke Vs. The Income Tax Officer (TDS), Alwar LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAALC 1579 N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Sh. Saajan Saini (Adv.) jktLo dh vksj ls@ Revenue b

For Appellant: Sh. Saajan Saini (Adv.)For Respondent: Sh. Arvind Kumar (CIT) &
Section 201(1)

delay of 232 days in filing the present appeal by the assessee is condoned in view of the decision of Hon’ble Conservator of Forest and Field Tiger Project Sariska vs. ITO(TDS) Supreme Court in the case of Collector, land Acquisition vs. Mst. Katiji and Others, 167 ITR 471 (SC) as the assessee is prevented by sufficient cause