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

Bench: the Ld. CIT(A), the assessee claimed that the delay was on account of ignorance of law and the assessee was alerted for filing the appeal only when they received a notice proposing levy of penalty u/s 271(1)(c) of the Act. Thereafter, the Ld. CIT(A) has discussed the issue of delayed filing with the help of several authorities on the subject and has declined to condone the said delay due to which the appeal was dismissed. 3.1 Further aggrieved with the action of Ld. CIT(A), the assessee is

condone the said delay due to which the appeal was dismissed. 3.1 Further aggrieved with the action of Ld. CIT(A), the assessee is in appeal before us with the following grounds: “1. For that the order of the learned assessing officer is bad both in law and on facts. 2. For that the learned assessing officer has erred