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46 results for “condonation of delay”+ Section 153A(1)(b)clear

Sorted by relevance

Chennai357Delhi280Mumbai169Hyderabad132Kolkata113Bangalore106Jaipur92Amritsar72Ahmedabad72Pune54Surat46Chandigarh33Rajkot23Visakhapatnam20Nagpur16Karnataka11Cuttack11Patna10Indore8Lucknow8Panaji7Jodhpur6Guwahati6Raipur6Cochin6Telangana5SC4Dehradun4Calcutta3Jabalpur2Orissa2Ranchi2Allahabad1

Key Topics

Section 271(1)(b)179Section 142(1)108Section 143(3)75Section 153A49Penalty40Addition to Income27Section 27426Section 13223Section 254(1)

HANSABEN MAGANBHAI VAGHASIYA,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 397/SRT/2022[2016-17]Status: DisposedITAT Surat10 Feb 2023AY 2016-17

Bench: Shri Pawan Singhita No. 393, 394, 395, 396, 397, 398 & 399/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Hansaben Maganbhai D.C.I.T., Vaghasiya, Central Circle-2, Vs. 174, Shree Gadhpur Surat. Township, Pasodara Gam, Ta- Kamrej, Surat-395206 Pan No. Adypv 3826 A Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3) r.w.s. 153A. 6. The ld. CIT(A) after considering

Showing 1–20 of 46 · Page 1 of 3

22
Search & Seizure21
Section 272A(1)(d)14
Limitation/Time-bar10

HANSABEN MAGANBHAI VAGHASIYA,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 395/SRT/2022[2014-15]Status: DisposedITAT Surat10 Feb 2023AY 2014-15

Bench: Shri Pawan Singhita No. 393, 394, 395, 396, 397, 398 & 399/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Hansaben Maganbhai D.C.I.T., Vaghasiya, Central Circle-2, Vs. 174, Shree Gadhpur Surat. Township, Pasodara Gam, Ta- Kamrej, Surat-395206 Pan No. Adypv 3826 A Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3) r.w.s. 153A. 6. The ld. CIT(A) after considering

HANSABEN MAGANBHAI VAGHASIYA,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 399/SRT/2022[2018-19]Status: DisposedITAT Surat10 Feb 2023AY 2018-19

Bench: Shri Pawan Singhita No. 393, 394, 395, 396, 397, 398 & 399/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Hansaben Maganbhai D.C.I.T., Vaghasiya, Central Circle-2, Vs. 174, Shree Gadhpur Surat. Township, Pasodara Gam, Ta- Kamrej, Surat-395206 Pan No. Adypv 3826 A Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3) r.w.s. 153A. 6. The ld. CIT(A) after considering

HANSABEN MAGANBHAI VAGHASIYA,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 393/SRT/2022[2012-13]Status: DisposedITAT Surat10 Feb 2023AY 2012-13

Bench: Shri Pawan Singhita No. 393, 394, 395, 396, 397, 398 & 399/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Hansaben Maganbhai D.C.I.T., Vaghasiya, Central Circle-2, Vs. 174, Shree Gadhpur Surat. Township, Pasodara Gam, Ta- Kamrej, Surat-395206 Pan No. Adypv 3826 A Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3) r.w.s. 153A. 6. The ld. CIT(A) after considering

HANSABEN MAGANBHAI VAGHASIYA,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 398/SRT/2022[2017-18]Status: DisposedITAT Surat10 Feb 2023AY 2017-18

Bench: Shri Pawan Singhita No. 393, 394, 395, 396, 397, 398 & 399/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Hansaben Maganbhai D.C.I.T., Vaghasiya, Central Circle-2, Vs. 174, Shree Gadhpur Surat. Township, Pasodara Gam, Ta- Kamrej, Surat-395206 Pan No. Adypv 3826 A Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3) r.w.s. 153A. 6. The ld. CIT(A) after considering

HANSABEN MAGANBHAI VAGHASIYA,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 396/SRT/2022[2015-16]Status: DisposedITAT Surat10 Feb 2023AY 2015-16

Bench: Shri Pawan Singhita No. 393, 394, 395, 396, 397, 398 & 399/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Hansaben Maganbhai D.C.I.T., Vaghasiya, Central Circle-2, Vs. 174, Shree Gadhpur Surat. Township, Pasodara Gam, Ta- Kamrej, Surat-395206 Pan No. Adypv 3826 A Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3) r.w.s. 153A. 6. The ld. CIT(A) after considering

HANSABEN MAGANBHAI VAGHASIYA,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 394/SRT/2022[2013-14]Status: DisposedITAT Surat10 Feb 2023AY 2013-14

Bench: Shri Pawan Singhita No. 393, 394, 395, 396, 397, 398 & 399/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Hansaben Maganbhai D.C.I.T., Vaghasiya, Central Circle-2, Vs. 174, Shree Gadhpur Surat. Township, Pasodara Gam, Ta- Kamrej, Surat-395206 Pan No. Adypv 3826 A Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3) r.w.s. 153A. 6. The ld. CIT(A) after considering

JAYESHKUMAR G. MACWAN,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 25/SRT/2023[2019-20]Status: DisposedITAT Surat31 Jan 2023AY 2019-20

Bench: Shri Pawan Singhita No. 391, 392/Srt/2022 &, 21 To 25/Srt/2023 (Assessment Years: 2013-14 To 2019-20) (Hearing In Virtual Court) Jayeshkumar G. Macwan, D.C.I.T., D-5/6 Uma Park, Opp. Central Circle-2, Vs. Green Valley Apt., B/H Surat. Gangeshwar Mahadev Temple, C.S. Marg, Adajan, Surat-395009. Pan No. Ahdpm 7194 D Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always cooperated during the assessment and finally order under Section 143(3) r.w.s. 153A. The ld. CIT(A) after considering the submission

JAYESHKUMAR G. MACWAN,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 23/SRT/2023[2017-18]Status: DisposedITAT Surat31 Jan 2023AY 2017-18

Bench: Shri Pawan Singhita No. 391, 392/Srt/2022 &, 21 To 25/Srt/2023 (Assessment Years: 2013-14 To 2019-20) (Hearing In Virtual Court) Jayeshkumar G. Macwan, D.C.I.T., D-5/6 Uma Park, Opp. Central Circle-2, Vs. Green Valley Apt., B/H Surat. Gangeshwar Mahadev Temple, C.S. Marg, Adajan, Surat-395009. Pan No. Ahdpm 7194 D Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always cooperated during the assessment and finally order under Section 143(3) r.w.s. 153A. The ld. CIT(A) after considering the submission

JAYESHKUMAR G. MACWAN,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 392/SRT/2022[2014-15]Status: DisposedITAT Surat31 Jan 2023AY 2014-15

Bench: Shri Pawan Singhita No. 391, 392/Srt/2022 &, 21 To 25/Srt/2023 (Assessment Years: 2013-14 To 2019-20) (Hearing In Virtual Court) Jayeshkumar G. Macwan, D.C.I.T., D-5/6 Uma Park, Opp. Central Circle-2, Vs. Green Valley Apt., B/H Surat. Gangeshwar Mahadev Temple, C.S. Marg, Adajan, Surat-395009. Pan No. Ahdpm 7194 D Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always cooperated during the assessment and finally order under Section 143(3) r.w.s. 153A. The ld. CIT(A) after considering the submission

JAYESHKUMAR G. MACWAN,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 21/SRT/2023[2015-16]Status: DisposedITAT Surat31 Jan 2023AY 2015-16

Bench: Shri Pawan Singhita No. 391, 392/Srt/2022 &, 21 To 25/Srt/2023 (Assessment Years: 2013-14 To 2019-20) (Hearing In Virtual Court) Jayeshkumar G. Macwan, D.C.I.T., D-5/6 Uma Park, Opp. Central Circle-2, Vs. Green Valley Apt., B/H Surat. Gangeshwar Mahadev Temple, C.S. Marg, Adajan, Surat-395009. Pan No. Ahdpm 7194 D Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always cooperated during the assessment and finally order under Section 143(3) r.w.s. 153A. The ld. CIT(A) after considering the submission

JAYESHKUMAR G. MACWAN,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 391/SRT/2022[2013-14]Status: DisposedITAT Surat31 Jan 2023AY 2013-14

Bench: Shri Pawan Singhita No. 391, 392/Srt/2022 &, 21 To 25/Srt/2023 (Assessment Years: 2013-14 To 2019-20) (Hearing In Virtual Court) Jayeshkumar G. Macwan, D.C.I.T., D-5/6 Uma Park, Opp. Central Circle-2, Vs. Green Valley Apt., B/H Surat. Gangeshwar Mahadev Temple, C.S. Marg, Adajan, Surat-395009. Pan No. Ahdpm 7194 D Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always cooperated during the assessment and finally order under Section 143(3) r.w.s. 153A. The ld. CIT(A) after considering the submission

JAYESHKUMAR G. MACWAN,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 22/SRT/2023[2016-17]Status: DisposedITAT Surat31 Jan 2023AY 2016-17

Bench: Shri Pawan Singhita No. 391, 392/Srt/2022 &, 21 To 25/Srt/2023 (Assessment Years: 2013-14 To 2019-20) (Hearing In Virtual Court) Jayeshkumar G. Macwan, D.C.I.T., D-5/6 Uma Park, Opp. Central Circle-2, Vs. Green Valley Apt., B/H Surat. Gangeshwar Mahadev Temple, C.S. Marg, Adajan, Surat-395009. Pan No. Ahdpm 7194 D Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always cooperated during the assessment and finally order under Section 143(3) r.w.s. 153A. The ld. CIT(A) after considering the submission

JAYESHKUMAR G. MACWAN,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 24/SRT/2023[2018-19]Status: DisposedITAT Surat31 Jan 2023AY 2018-19

Bench: Shri Pawan Singhita No. 391, 392/Srt/2022 &, 21 To 25/Srt/2023 (Assessment Years: 2013-14 To 2019-20) (Hearing In Virtual Court) Jayeshkumar G. Macwan, D.C.I.T., D-5/6 Uma Park, Opp. Central Circle-2, Vs. Green Valley Apt., B/H Surat. Gangeshwar Mahadev Temple, C.S. Marg, Adajan, Surat-395009. Pan No. Ahdpm 7194 D Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always cooperated during the assessment and finally order under Section 143(3) r.w.s. 153A. The ld. CIT(A) after considering the submission

DCIT, CENTRAL CIRCLE-2, SURAT, SURAT vs. DHANPRIYA PRINTS PVT. LTD.,, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

ITA 52/SRT/2022[2015-16]Status: DisposedITAT Surat23 Dec 2022AY 2015-16

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rasesh Shah, CAFor Respondent: Sr. DR
Section 143(3)

condone these minor delays in filing appeals and admit these three appeals for hearing on merit. 4. Although, these appeals filed by the Assessee and Revenue, contain multiple grounds of appeals. However, at the time of hearing, we have carefully perused all the grounds raised by the Revenue as well as by the Assessee. We note that most

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, SURAT vs. BETEX INDIA LIMITED, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

ITA 174/SRT/2021[2008-9]Status: DisposedITAT Surat23 Dec 2022

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rasesh Shah, CAFor Respondent: Sr. DR
Section 143(3)

condone these minor delays in filing appeals and admit these three appeals for hearing on merit. 4. Although, these appeals filed by the Assessee and Revenue, contain multiple grounds of appeals. However, at the time of hearing, we have carefully perused all the grounds raised by the Revenue as well as by the Assessee. We note that most

BETEX INDIA LIMITED,SURAT vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

ITA 171/SRT/2021[2008-09]Status: DisposedITAT Surat23 Dec 2022AY 2008-09

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

For Appellant: Shri Rasesh Shah, CAFor Respondent: Sr. DR
Section 143(3)

condone these minor delays in filing appeals and admit these three appeals for hearing on merit. 4. Although, these appeals filed by the Assessee and Revenue, contain multiple grounds of appeals. However, at the time of hearing, we have carefully perused all the grounds raised by the Revenue as well as by the Assessee. We note that most

JIGNA JAYESHKUMAR MACWAN,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-2, SURAT, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 410/SRT/2022[2013-14]Status: DisposedITAT Surat31 Jan 2023AY 2013-14

Bench: Shri Pawan Singhita No. 410, 411, 412, 413, 414, 415 & 416/Srt/2022 (Assessment Years: 2013-14 To 2019-20) (Hearing In Virtual Court) Jigna Jayeshkumar D.C.I.T., Macwan, Central Circle-2, Vs. D-5/6 Uma Park, Opp. Surat. Green Valley Apt., C.S. Marg, Adajan, Surat- 395009. Pan No. Amkpm 9536 F Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3) r.w.s. 153A. The ld. CIT(A) after considering the submission

JIGNA JAYESHKUMAR MACWAN,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-2, SURAT, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 412/SRT/2022[2015-16]Status: DisposedITAT Surat31 Jan 2023AY 2015-16

Bench: Shri Pawan Singhita No. 410, 411, 412, 413, 414, 415 & 416/Srt/2022 (Assessment Years: 2013-14 To 2019-20) (Hearing In Virtual Court) Jigna Jayeshkumar D.C.I.T., Macwan, Central Circle-2, Vs. D-5/6 Uma Park, Opp. Surat. Green Valley Apt., C.S. Marg, Adajan, Surat- 395009. Pan No. Amkpm 9536 F Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3) r.w.s. 153A. The ld. CIT(A) after considering the submission

JIGNA JAYESHKUMAR MACWAN,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-2, SURAT, SURAT

In the result, ground of appeal raised by assessee is allowed

ITA 413/SRT/2022[2016-17]Status: DisposedITAT Surat31 Jan 2023AY 2016-17

Bench: Shri Pawan Singhita No. 410, 411, 412, 413, 414, 415 & 416/Srt/2022 (Assessment Years: 2013-14 To 2019-20) (Hearing In Virtual Court) Jigna Jayeshkumar D.C.I.T., Macwan, Central Circle-2, Vs. D-5/6 Uma Park, Opp. Surat. Green Valley Apt., C.S. Marg, Adajan, Surat- 395009. Pan No. Amkpm 9536 F Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 153ASection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

delay due to Covid-19 pandemic due to second wave everywhere and everyone was doing work with proper safety measure. Thus, such non-compliance should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3) r.w.s. 153A. The ld. CIT(A) after considering the submission