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3,795 results for “condonation of delay”+ Section 6(1)clear

Sorted by relevance

Chennai3,984Mumbai3,795Delhi2,972Pune2,149Kolkata2,048Bangalore1,671Ahmedabad1,537Hyderabad1,330Jaipur978Patna727Chandigarh643Surat641Cochin605Visakhapatnam512Nagpur498Indore465Raipur411Lucknow380Amritsar355Cuttack335Rajkot303Karnataka296Panaji201Agra147Guwahati105Jodhpur102Dehradun99Calcutta87Allahabad69Ranchi66Jabalpur66SC62Telangana46Varanasi38Andhra Pradesh16Rajasthan10Orissa9Kerala7Punjab & Haryana6Himachal Pradesh4A.K. SIKRI ROHINTON FALI NARIMAN2Gauhati1DIPAK MISRA R.K. AGRAWAL PRAFULLA C. PANT1A.K. SIKRI N.V. RAMANA1VIKRAMAJIT SEN SHIVA KIRTI SINGH1R.M. LODHA ANIL R. DAVE1

Key Topics

Addition to Income56Section 25041Section 143(3)38Section 14737Condonation of Delay34Section 143(1)30Section 12A27Disallowance26Section 144

JAN SEVA MANDAL ,MUMBAI vs. INCOME TAX OFFICER EXEMPTION WARD -1(4), MUMBAI

In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for statisti...

ITA 3445/MUM/2025[2023-24]Status: DisposedITAT Mumbai22 Jul 2025AY 2023-24

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2023-24 Jan Seva Mandal, Central Processing Centre Income Vinayalaya, Mahakali Caves Tax Deparment, Bengaluru, Vs. Road, Andheri (East), Income Tax Officer Exemption Mumbai-400093. Ward 1(4), Mumbai. 6Th Floor, Mtnl Te Building, Pedder Road, Mumbai-400026. Pan No. Aaatj 4868 K Appellant Respondent

For Appellant: Mr. Ketan PatelFor Respondent: Mr. Vivek Perampurna, CIT-DR
Section 11Section 12ASection 143(1)

6) was disallowed and consequential adjustments were made under Section 143(1)(a) of the Act. were made under Section 143(1)(a) of the Act. 3. In appeal, the Ld. CIT(A) affirmed In appeal, the Ld. CIT(A) affirmed the adjustments made by the adjustments made by the CPC, holding that the audit report was not filed within

Showing 1–20 of 3,795 · Page 1 of 190

...
25
Deduction24
Section 26323
Limitation/Time-bar22

TASKUS INDIA PRIVATE LIMITED,MUMBAI vs. CIRCLE 8(3)(1), MUMBAI

ITA 2826/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Jun 2025AY 2022-23

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2022-23 M/S Taskus India Pvt. Ltd., 1. Dy. Director Of Income- Ttc Industrial Area, Tower -9, Tax Central Processing Vs. Gigaplex It Park, 18Th & 19Th Centre Unit, Bengaluru, Floor, Midc, Plot No. 1 I.T.5, 1St Floor, Prestige Alpha Airoli Knowledge Park Rd, Airoli, No 48/1, 48/2 Navi Mumbai-400708. Beratenaagrahara Begur Hosur Rd Uttarahali Hobli, Bengaluru- 560100. 2. The Dy. Cit, Circle 8(3)(1), Mumbai. Aayakar Bhavan, M.K. Road, Mumbai-400020. Pan No. Aahct 0980 G Appellant Respondent

For Appellant: Mr. Tata Krishna
Section 143(1)Section 143(3)Section 246A(1)(a)Section 80ASection 80J

6 pertain to the scope and authority of the Centralized Processing Centre (CPC) to effect an authority of the Centralized Processing Centre (CPC) to effect an authority of the Centralized Processing Centre (CPC) to effect an adjustment under Section 143(1) of the Act adjustment under Section 143(1) of the Act by disallowing a claim by disallowing a claim

SHREE PUSHKAR FOUNDATION,MUMBAI vs. INCOME TAX OFFICER (EXEMPTION)-WARD 2(30, MUMBAI

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

ITA 2714/MUM/2024[2021-22]Status: DisposedITAT Mumbai30 Aug 2024AY 2021-22

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2021-22 Shree Pushkar Foundation, Ito (Exemption) – Ward 2(3), 301/302, 3Rd Floor, Cumbala Hill Tele Exchange Atlanta Centre, Vs. (Mtnl), Peddar Rd, Tardeo, Near Udyog Bhavan, Mumbai-400026. Sonawala Road, Goregaon East, Mumbai-400063. Pan No. Aawts 2303 N Appellant Respondent

For Appellant: Mr. Sandip S. Nagar, &For Respondent: 24/07/2024
Section 11Section 11(2)Section 139(1)Section 143(1)Section 143(1)(a)

6. In the present case, the High Court as well as the ITAT have observed and held that for claiming the so observed and held that for claiming the so-called exemption relief under called exemption relief under section 10B (8) of the IT Act, furnishing the declaration to the as section 10B (8) of the IT Act, furnishing

ARTI SHAILEN TOPIWALA,ANDHERI WEST, MUMBAI vs. ITO, WARD 34(1)(1), MUMBAI, BKC, BANDRA EAST, MUMBAI

In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for statisti...

ITA 4383/MUM/2025[2013-2014]Status: DisposedITAT Mumbai26 Aug 2025AY 2013-2014

Bench: Shri Sandeep Gosain () & Om Prakash Kant () Ita No. 4383 & 4384/Mum/2025 Assessment Year: 2013-14 Arti Shailen Topiwala Ito, Ward 34(1)(1), Mumbai B-701, Parimal Apartment, C.D. Income Tax Appellate Barfiwala Road, Andheri West, Vs. Tribunal, Mumbai- 400058 Mumbai- 400020 Pan No. Aacpt 3505 D Appellant Respondent

For Appellant: Mr. Rajesh ShahFor Respondent: Mr. Surendra Mohan –SR. DR
Section 271Section 271(1)(b)

6,38,220/-. The said return was . The said return was selected for scrutiny and statutory notice under section 143(2) of selected for scrutiny and statutory notice under section 143(2) of selected for scrutiny and statutory notice under section 143(2) of the Income-tax Act, 1961 (‘the Act’) was duly issued and served

ARTI SHAILEN TOPIWALA,ANDHERI WEST, MUMBAI vs. ITO, WARD 34(1)(1), MUMBAI, BKC, BANDRA EAST, MUMBAI

In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for statisti...

ITA 4384/MUM/2025[2013-2014]Status: DisposedITAT Mumbai26 Aug 2025AY 2013-2014

Bench: Shri Sandeep Gosain () & Om Prakash Kant () Ita No. 4383 & 4384/Mum/2025 Assessment Year: 2013-14 Arti Shailen Topiwala Ito, Ward 34(1)(1), Mumbai B-701, Parimal Apartment, C.D. Income Tax Appellate Barfiwala Road, Andheri West, Vs. Tribunal, Mumbai- 400058 Mumbai- 400020 Pan No. Aacpt 3505 D Appellant Respondent

For Appellant: Mr. Rajesh ShahFor Respondent: Mr. Surendra Mohan –SR. DR
Section 271Section 271(1)(b)

6,38,220/-. The said return was . The said return was selected for scrutiny and statutory notice under section 143(2) of selected for scrutiny and statutory notice under section 143(2) of selected for scrutiny and statutory notice under section 143(2) of the Income-tax Act, 1961 (‘the Act’) was duly issued and served

NAUSHAD ALI ABDUL HAQ SHAIKH,MUMBAI vs. INCOME TAX OFFICER 42(2)(4), MUMBAI

ITA 7338/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Akshay JainFor Respondent: Mr. Swapnil Choudhari, Sr. DR
Section 245

1. The Commissioner (Appeals) may ) may admit an appeal after the ppeals) may ) may admit an appeal after the expiration of the said period if he is satisfied that the appellant had expiration of the said period if he is satisfied that the appellant had expiration of the said period if he is satisfied that the appellant had sufficient cause

NAUSHAD ALI ABDUL HAQ SHAIK,MUMBAI vs. INCOME TAX OFFICER 42(2)(4), MUMBAI

ITA 7339/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Akshay JainFor Respondent: Mr. Swapnil Choudhari, Sr. DR
Section 245

1. The Commissioner (Appeals) may ) may admit an appeal after the ppeals) may ) may admit an appeal after the expiration of the said period if he is satisfied that the appellant had expiration of the said period if he is satisfied that the appellant had expiration of the said period if he is satisfied that the appellant had sufficient cause

CCI CHAMBERS CO-OP HSG SOC. LTD,MUMBAI vs. INCOME TAX OFFICER-17(2)(1), MUMBAI

In the result, both the appeal

ITA 3543/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Jul 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Appellant: Mr. Pravin Salunkhe, Sr. DRFor Respondent: Mr. Prakash Jotwani

delay is condoned. The ground No. 1 raised in the appeal is accordingly allowed for statistical No. 1 raised in the appeal is accordingly allowed for statistical No. 1 raised in the appeal is accordingly allowed for statistical purposes. 4. As regards Ground No. 2, which concerns the merits of the As regards Ground No. 2, which concerns the merits

CCI CHAMBERS CO-OP HSG SOC. LTD,MUMBAI vs. ITO 17(2)(1), MUMBAI

In the result, both the appeal

ITA 3542/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jul 2025AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Appellant: Mr. Pravin Salunkhe, Sr. DRFor Respondent: Mr. Prakash Jotwani

delay is condoned. The ground No. 1 raised in the appeal is accordingly allowed for statistical No. 1 raised in the appeal is accordingly allowed for statistical No. 1 raised in the appeal is accordingly allowed for statistical purposes. 4. As regards Ground No. 2, which concerns the merits of the As regards Ground No. 2, which concerns the merits

GETINGE MEDICAL INDIA PRIVATE LIMITED ,MUMBAI vs. DCIT 2(2)(1), MUMBAI MAHARASHTRA

In the result, appeal filed by the assessee stands partly allowed

ITA 4872/MUM/2024[2020-21]Status: DisposedITAT Mumbai13 Mar 2026AY 2020-21

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 115Section 115BSection 142(1)Section 143(2)Section 156Section 234ASection 270ASection 37Section 41Section 41(1)(a)

6. The current appeal of the assessee is against the order under section 143(3) r.w.s. 144C(13) r.w.s. 1443 of the Act, dated 23- 9 Getinge Medical India Private Limited 07-2024. In an appeal against the order under section 143(3), the additions/dis-allowances made in intimation under section 143(1) cannot be challenged, as there is no automatic

KUDOS FINANCE AND INVESTMENT PVT LTD,MUMBAI vs. PRINCIPLE COMMISSIONER OF INCOME TAX-6, MUMBAI

ITA 3075/MUM/2024[2019-20]Status: DisposedITAT Mumbai14 May 2025AY 2019-20

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Abhilash HiranFor Respondent: Shri Biswanath Das
Section 143(1)Section 143(1)(a)Section 253(1)(c)Section 263Section 36(1)

delay of 372 days in filing the present appeal is condoned. Accordingly, we proceed to adjudicate the grounds/additional grounds raised by the Assessee in the present appeal. 8. It is admitted position that the Assessee had returned loss for the Assessment Year 2019-2020. It has not been disputed by the Assessee that as per Section 36(1)(viia

UMMEED FOUNDATION,AL SHAKREEN APT vs. COMMISSIONER OF INCOME TAX (EXEMPTION), PUNE, PMT BUILDING COMMERCIAL COMPLEX

In the result, the grounds of the assessee are allowed for In the result, the grounds of the assessee are allowed for In the result, the grounds of the assessee are allowed for statistical purposes

ITA 1876/MUM/2024[2023-24]Status: DisposedITAT Mumbai24 Jul 2024AY 2023-24

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2023-24 Ummeed Foundation, Cit(E), Pune, Room No. 204, A1 Shakreen Apt, 322, 3Rd Floor, Income Tax Vs. Waf Acomplex Chs, H-104, Office, Pmt Building Sharifa Road, Amrut Nagar, City Commercial Complex, Shankar Convent High School, Thane, Sheth Road, Swargate, Kausa B.O., Maharashtra-400612. Pune-411037. Pan No. Aaatu 4914 H Appellant Respondent

For Appellant: Mr. Ankush Kapoor, CIT-DRFor Respondent: Mr. Rohan Dedhia
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)Section 80G(5)(iv)

6 Form No. 10AB, in case of Form No. 10AB, in case of an application under clause (iii an application under clause (iii) of the first proviso to clause (23C) of section 10 or under sub first proviso to clause (23C) of section 10 or under sub first proviso to clause (23C) of section 10 or under sub-clause

MTITANIUM APARTMENTS PVT LTD,MUMBAI vs. DY. CIT CIRCLE 1(2)(1), MUMBAI

In the result, the appeal of the assessee is dismissed

ITA 4694/MUM/2025[2024-25]Status: DisposedITAT Mumbai09 Sept 2025AY 2024-25

Bench: Shri Om Prakash Kant () & Ms. Suchitra Raghunath Kamble () Assessment Year: 2024-2025 Mtitanium Apartments Pvt. Ltd., Dy. Cit-Circle 1(2)(1), 2Nd Floor, Shreeniwas House, Range 412, Aayakar Bhawan, Hazarimal Somani Marg, Fort, Vs. M.K. Road, Churchgate, Mumbai-400 001. Mumbai-400020. Pan No. Aafcm 6810 Q Appellant Respondent

For Appellant: Mr. Narayn AtalFor Respondent: Ms. Kavitha Kaushik, Sr. DR
Section 139(1)Section 143(1)

condonation of delay, if so advised. of delay, if so advised. Mtitanium Apartments Pvt. Ltd Mtitanium Apartments Pvt. Ltd 5.1 In the present case, there is no dispute that the return for In the present case, there is no dispute that the return for In the present case, there is no dispute that the return for assessment year 2023 assessment

NOBEL BIOCARE INDIA PRIVATE LIMITED ,MUMBAI vs. ACIT, CIRCLE 15(2)(1), MUMBAI

ITA 6880/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Hinal Shah &For Respondent: Mr. Leyaqat Ali Aafaqui, Sr. DR

1,53,70,532 under section 43B of the IT Act to the total income with respect to the section 43B of the IT Act to the total income with respect to the section 43B of the IT Act to the total income with respect to the bonus paid by the Appellant on or before due date prescribed for bonus

NOBEL BIOCARE INDIA PRIVATE LIMITED ,MUMBAI vs. ACIT, 15(2)(1), MUMBAI

ITA 6881/MUM/2025[2020-21]Status: DisposedITAT Mumbai09 Feb 2026AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Hinal Shah &For Respondent: Mr. Leyaqat Ali Aafaqui, Sr. DR

1,53,70,532 under section 43B of the IT Act to the total income with respect to the section 43B of the IT Act to the total income with respect to the section 43B of the IT Act to the total income with respect to the bonus paid by the Appellant on or before due date prescribed for bonus

KUDOS FINANCE AND INVESTMENTS PVT. LTD.,PUNE vs. ITO, WARD-14 (2)(1), MUMBAI

ITA 3015/MUM/2024[2019-20]Status: DisposedITAT Mumbai14 May 2025AY 2019-20
For Appellant: Shri Abhilash HiranFor Respondent: Shri Biswanath Das
Section 143(1)Section 143(1)(a)Section 263Section 36(1)(viia)

6: Without prejudice to Ground 4, the learned PCIT erred in\nlaw in setting aside the intimation passed under section\n143(1) of the Act by giving directions to the teamed AD\nfor making an enquiry with respect to claim made under\nsection 36(1)(viia) of the Act violating the scope of Section\n143(1) of the Act where

M/S. LAVINO KAPUR COTTONS PVT. LTD,MUMBAI vs. DCIT CIR 3(2) (1) , MUMBAI

In the result, both the appeals filed by the assessee are allowed

ITA 2102/MUM/2021[2017-18]Status: DisposedITAT Mumbai29 Jun 2022AY 2017-18

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 2102 & 2103/Mum/2021 (निर्धारणवर्ा / Assessment Year: 2017-18 & 2018-19) Dcit Cir-3(2)(1), M/S Lavino Kapur Cottons Aayakar Bhavan, Pvt. Ltd. बिधम/ Maharshi Karve Road, 121/122, Mittal Chambers, Vs. Churchgate, Nariman Point, Mumbai-400 020 Mumbai-400 021 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaacl0824C (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Surinder Mehra, Ld. Ar प्रत्यथीकीओरसे/Respondent By : Shri Mehul Jain, Ld. Dr सुनवाईकीतारीख/ : 02.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeals Have Been Filed By The Assessee Against The Separate Impugned Order Of Even Date 10.09.2021, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2017-18 & 2018-19. 2

For Appellant: Shri Surinder Mehra, LdFor Respondent: Shri Mehul Jain, Ld. DR
Section 143(1)Section 143(1)(a)Section 3Section 36(1)(va)Section 43B

delay in filing the appeals and there is a reasonable cause, therefore appeal of the assessee is condoned. 4. The ground taken before us is that, Ld. First Appellate Authority has erred in law and on facts in holding addition u/s 3 I.T.A. No. 2102 & 2103/Mum/2021 M/S Lavino Kapur Cottons Pvt. Ltd 36(1)(va) on account of late deposit

SHREE DADAR JAIN PAUSHADHSHALA TRUST,MUMBAI vs. ITO (E_ - 1(2), MUMBAI

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

ITA 2061/MUM/2019[2014-15]Status: DisposedITAT Mumbai19 Aug 2019AY 2014-15

Bench: Shri Pawan Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.2061/Mum/2019 (नििाारण वर्ा / Assessment Year: 2014-15) बिाम/ Shree Dadar Jain Ito(E)-1(2) Paushadhshala Trust, Room No. 501, 5 Th Floor, Aaradhana Bhavan, Piramal Chambers, V. 289, S K Bole Road, Lalbaug, Parel, Dadar West, Mumbai-400012 Mumbai-400028 स्थायी ऱेखा सं./ Pan: Aaats7848E (अपीऱाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri. Bhadresh Doshi Revenue By: Shri. Abhi Rama Karthikeyn S. सुनवाई की तारीख /Date Of Hearing : 03.06.2019 घोषणा की तारीख /Date Of Pronouncement : 19.08.2019 आदेश / O R D E R Per Ramit Kochar: This Appeal, Filed By Assessee, Being Ita No. 2061/Mum/2019, Is Directed Against Appellate Order Dated 08/02/2019, Passed By Learned Commissioner Of Income Tax (Appeals)-3, Mumbai (Hereinafter Called ―The Cit(A)‖) In Appeal Number Cit(A)-3/It-10394/2017-18, For Assessment Year 2014-15, The Appellate Proceedings Had Arisen Before Learned Cit(A) From Assessment Order Dated 28.12.2006 Passed By Learned Assessing Officer (Hereinafter Called ―The Ao‖) U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Called ―The Act‖) For Ay:2014-15. 2. The Grounds Of Appeal Raised By Assessee In Memo Of Appeal Filed With The Income-Tax Appellate Tribunal, Mumbai (Hereinafter Called ―The Tribunal‖) Read As Under:-

For Appellant: Shri. Bhadresh DoshiFor Respondent: Shri. Abhi Rama Karthikeyn S
Section 11(1)Section 11(1)(a)Section 11(2)Section 12ASection 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)

6. It is abundantly clear from the wordings of sub-section (2) of section 11 that it is mandatory for the person claiming the benefit of section 11 to intimate to the assessing authority the particulars required under rule 17 in Form No. 10 of the Act. If during the assessment proceedings the Assessing Officer does not have the necessary

DCIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

The appeal of the Revenue is dismissed

ITA 1360/MUM/2016[1995-96]Status: DisposedITAT Mumbai21 May 2018AY 1995-96

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 1995-96 Dcit-2(2)(1), M/S State Bank Of India, R. No.545, Financial Reporting & बनाम/ Aayakar Bhavan Taxation Department, 3Rd Vs. M.K. Road, Floor, Corporate Centre, Mumbai-400020 State Bank Bhavan, Madam Cama Road, Nariman Point, Mumbai-400021 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aaacs8577K

Section 244ASection 51

condonation of delay has to be treated as attributable to the assessee while determining the eligible interest in terms of section 244A(2)of the Act.In other words,if an assessee is responsible for the delay in the finalisation of the proceedings on the basis of which he becomes entitled to the refund, then the period of delay

VIIKING MEDIA & ENTERTAINMENT PVT. LTD,MUMBAI vs. ACIT (IT) CENTRAL CIR4(4), MUMBAI

In the result, appeal filed by the assessee is partly allowed as indicated above

ITA 2384/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Feb 2023AY 2016-17

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms Kavitha Rajagopal, Hon'Blev. Acit – Central Circle-4(4) Viiking Media & Entertainment Pvt Ltd., 604-065, 6Th Floor, Gateway Plaza, Air India Building Hiranandani Garden Nariman Point, Mumbai – 400 021 Central Avenue, Powai, Mumbai - 400076 Pan: Aaacj9884E (Appellant) (Respondent) Shri Neelkant Khandelwal Assessee Represented By : Ms. Richa Gulati Department Represented By :

6. Therefore, we hereby condone the delay in filing of appeal by the assessee and proceed to adjudicate the appeal on merit. 7. The assessee has raised the following grounds of appeal in the memorandum of appeal filed in Form no 36 :– “The following grounds of appeal are independent of and without prejudice to one another – 1. The Assistant Commissioner