In the result, all the captioned seven appeal are allowed for statistical purposes
Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member
271F are unjustified, as the failure to file the return was due to operational shutdown and not due to any intention to evade tax. Moreover, taxes had already been paid in excess. 8. Procedural Lapses in Appeal Proceedings: The Learned Commissioner of Appeals failed to give proper consideration to the condonation of delay and the reasons for the late filing