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31 results for “condonation of delay”+ Section 249(4)(b)clear

Sorted by relevance

Mumbai118Chennai94Chandigarh94Bangalore79Kolkata79Ahmedabad75Delhi61Raipur55Hyderabad44Jaipur40Pune39Surat31Lucknow30Indore21Panaji20Patna15Visakhapatnam12Jabalpur9Amritsar9Guwahati9Nagpur9Rajkot7Agra4Cuttack4Allahabad3Jodhpur3Ranchi2Varanasi2SC2Dehradun2Cochin1

Key Topics

Section 271(1)(b)74Section 69A59Section 142(1)40Section 271(1)(c)24Penalty24Section 14419Addition to Income15Section 143(3)14Section 250

BHARATBHAI NAGINBHAI PATEL,ANKLESHWAR vs. INCOME TAX OFFICER, WARD - 2(4), BHARUCH

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

ITA 393/SRT/2023[2012-13]Status: DisposedITAT Surat30 Oct 2023AY 2012-13

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita No.393/Srt/2023 Assessment Year: (2012-13) (Physical Hearing) Bharatbhai Nagjibhai Patel, Vs. The Ito, 392, Nishal Faliu, Nava Haripura, Ward- 2(4), Sajod, Ankleshwar, Bharuch, Bharuch, Gujarat – 393020. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bpppp4227M (Appellant) (Respondent) Shri Ashutosh P. Nanavaty, Ca Appellant By Shri Vinod Kumar, Sr. Dr Respondent By Date Of Hearing 16/10/2023 Date Of Pronouncement 30/10/2023

Section 143(3)Section 249(3)

4. On the other hand, ld. Sr. DR for the Revenue submitted that delay before the NFAC/ld. CIT(A) should not be condoned by the Tribunal. Let the assessee be filed a petition for condonation of delay before the NFAC/ld. CIT(A) and NFAC/ld. CIT(A) should take independent decision to condone the delay of (649) days

NAROTTAMBHAI CHHOTUBHAI PATEL,SURAT vs. INCOME TAX OFFICER, WARD 2(3)(1), SURAT

Showing 1–20 of 31 · Page 1 of 2

14
Section 1478
Reopening of Assessment4
Natural Justice3

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1185/SRT/2025[2015-16]Status: HeardITAT Surat30 Jan 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 144Section 147Section 249(4)(b)Section 250

Delay condoned. This appeal has been filed by the assessee against the order dated 06.11.2024 passed by the Ld. Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as the “Ld. CIT(A)”), under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as the “Act”) for Assessment Year

JAYSHREEBEN NILAMKUMAR DESAI,NA vs. ARIVS.INCOME TAX OFFICER, WARD-3, NAVSARI

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

ITA 176/SRT/2023[2011-12]Status: DisposedITAT Surat17 Apr 2023AY 2011-12

Bench: Shri Pawan Singh(Virtual Hearing) Jayshreeben Nilamkumar Desai, I.T.O., Saket, New Patel Nagar Society, Chhapra Ward-3, Vs. Road, Navsari. Navsari. Pan No. Ambpd 8733 A Appellant/ Assessee Respondent/ Revenue

Section 144Section 147Section 254(1)

Section 249(2)(b) and 249(3) of the Act. Thus, the delay was not condoned and appeal was dismissed as unadmitted. As recorded 5 Jayshreeben Nilamkumar Desai Vs ITO above, before me, the ld. AR of the assessee while making her submission vehemently contended that the assessee has good case on merit as the revenue has taxed the same

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 633/SRT/2023[2014-15]Status: HeardITAT Surat21 Nov 2023AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

Section 142Section 142(1)Section 143(3)Section 144Section 271(1)Section 271(1)(b)

4. Succinct facts qua the issue are that during the assessment proceedings, the Assessing Officer observed that assessee has failed to comply with the terms of statutory notice issued under section 142(1) on 02.12.2020 and 22.12.2020 of the Income Tax Act, 1961. The Assessing Officer noted that there is an onus on the assessee to produce the requisite details

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 634/SRT/2023[2015-16]Status: HeardITAT Surat21 Nov 2023AY 2015-16

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

Section 142Section 142(1)Section 143(3)Section 144Section 271(1)Section 271(1)(b)

4. Succinct facts qua the issue are that during the assessment proceedings, the Assessing Officer observed that assessee has failed to comply with the terms of statutory notice issued under section 142(1) on 02.12.2020 and 22.12.2020 of the Income Tax Act, 1961. The Assessing Officer noted that there is an onus on the assessee to produce the requisite details

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 635/SRT/2023[2016-17]Status: HeardITAT Surat21 Nov 2023AY 2016-17

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

Section 142Section 142(1)Section 143(3)Section 144Section 271(1)Section 271(1)(b)

4. Succinct facts qua the issue are that during the assessment proceedings, the Assessing Officer observed that assessee has failed to comply with the terms of statutory notice issued under section 142(1) on 02.12.2020 and 22.12.2020 of the Income Tax Act, 1961. The Assessing Officer noted that there is an onus on the assessee to produce the requisite details

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 636/SRT/2023[2017-18]Status: HeardITAT Surat21 Nov 2023AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

Section 142Section 142(1)Section 143(3)Section 144Section 271(1)Section 271(1)(b)

4. Succinct facts qua the issue are that during the assessment proceedings, the Assessing Officer observed that assessee has failed to comply with the terms of statutory notice issued under section 142(1) on 02.12.2020 and 22.12.2020 of the Income Tax Act, 1961. The Assessing Officer noted that there is an onus on the assessee to produce the requisite details

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 637/SRT/2023[2018-19]Status: HeardITAT Surat21 Nov 2023AY 2018-19

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

Section 142Section 142(1)Section 143(3)Section 144Section 271(1)Section 271(1)(b)

4. Succinct facts qua the issue are that during the assessment proceedings, the Assessing Officer observed that assessee has failed to comply with the terms of statutory notice issued under section 142(1) on 02.12.2020 and 22.12.2020 of the Income Tax Act, 1961. The Assessing Officer noted that there is an onus on the assessee to produce the requisite details

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 631/SRT/2023[2012-13]Status: HeardITAT Surat21 Nov 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

Section 142Section 142(1)Section 143(3)Section 144Section 271(1)Section 271(1)(b)

4. Succinct facts qua the issue are that during the assessment proceedings, the Assessing Officer observed that assessee has failed to comply with the terms of statutory notice issued under section 142(1) on 02.12.2020 and 22.12.2020 of the Income Tax Act, 1961. The Assessing Officer noted that there is an onus on the assessee to produce the requisite details

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 632/SRT/2023[2013-14]Status: HeardITAT Surat21 Nov 2023AY 2013-14

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

Section 142Section 142(1)Section 143(3)Section 144Section 271(1)Section 271(1)(b)

4. Succinct facts qua the issue are that during the assessment proceedings, the Assessing Officer observed that assessee has failed to comply with the terms of statutory notice issued under section 142(1) on 02.12.2020 and 22.12.2020 of the Income Tax Act, 1961. The Assessing Officer noted that there is an onus on the assessee to produce the requisite details

RAMABHAI KANJIBHAI PATEL,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 108/SRT/2023[2015-16]Status: DisposedITAT Surat11 May 2023AY 2015-16

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.106 To 110/Srt/2023 Assessment Years: (2013-14 To 2017-18) (Physical Hearing) Ramabhai Kanjibhai Patel, Vs. The Dcit, At-Surajpuja, Po-Surajpura, Ta-Palanpur, Central Circle-2, Palanpur-385001. Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aefpp4997J (Assessee) (Respondent)

Section 142(1)Section 143(3)Section 144Section 271Section 271(1)(b)Section 274

delay in filing submission should not be constructed strictly, more so when the assessee has co-operated and replied and attended all the hearings. 7. On the other hand, Ld. DR for the Revenue submitted that assessee did not make the compliance of various notices during the assessment proceedings, so penalty should be levied under section 271(1)(b

RAMABHAI KANJIBHAI PATEL,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 109/SRT/2023[2016-17]Status: DisposedITAT Surat11 May 2023AY 2016-17

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.106 To 110/Srt/2023 Assessment Years: (2013-14 To 2017-18) (Physical Hearing) Ramabhai Kanjibhai Patel, Vs. The Dcit, At-Surajpuja, Po-Surajpura, Ta-Palanpur, Central Circle-2, Palanpur-385001. Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aefpp4997J (Assessee) (Respondent)

Section 142(1)Section 143(3)Section 144Section 271Section 271(1)(b)Section 274

delay in filing submission should not be constructed strictly, more so when the assessee has co-operated and replied and attended all the hearings. 7. On the other hand, Ld. DR for the Revenue submitted that assessee did not make the compliance of various notices during the assessment proceedings, so penalty should be levied under section 271(1)(b

RAMABHAI KANJIBHAI PATEL,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 106/SRT/2023[2013-14]Status: DisposedITAT Surat11 May 2023AY 2013-14

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.106 To 110/Srt/2023 Assessment Years: (2013-14 To 2017-18) (Physical Hearing) Ramabhai Kanjibhai Patel, Vs. The Dcit, At-Surajpuja, Po-Surajpura, Ta-Palanpur, Central Circle-2, Palanpur-385001. Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aefpp4997J (Assessee) (Respondent)

Section 142(1)Section 143(3)Section 144Section 271Section 271(1)(b)Section 274

delay in filing submission should not be constructed strictly, more so when the assessee has co-operated and replied and attended all the hearings. 7. On the other hand, Ld. DR for the Revenue submitted that assessee did not make the compliance of various notices during the assessment proceedings, so penalty should be levied under section 271(1)(b

RAMABHAI KANJIBHAI PATEL,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 107/SRT/2023[2014-15]Status: DisposedITAT Surat11 May 2023AY 2014-15

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.106 To 110/Srt/2023 Assessment Years: (2013-14 To 2017-18) (Physical Hearing) Ramabhai Kanjibhai Patel, Vs. The Dcit, At-Surajpuja, Po-Surajpura, Ta-Palanpur, Central Circle-2, Palanpur-385001. Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aefpp4997J (Assessee) (Respondent)

Section 142(1)Section 143(3)Section 144Section 271Section 271(1)(b)Section 274

delay in filing submission should not be constructed strictly, more so when the assessee has co-operated and replied and attended all the hearings. 7. On the other hand, Ld. DR for the Revenue submitted that assessee did not make the compliance of various notices during the assessment proceedings, so penalty should be levied under section 271(1)(b

RAMABHAI KANJIBHAI PATEL,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, SURAT

In the result, appeals filed by assessee (in ITA Nos

ITA 110/SRT/2023[2017-18]Status: DisposedITAT Surat11 May 2023AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.106 To 110/Srt/2023 Assessment Years: (2013-14 To 2017-18) (Physical Hearing) Ramabhai Kanjibhai Patel, Vs. The Dcit, At-Surajpuja, Po-Surajpura, Ta-Palanpur, Central Circle-2, Palanpur-385001. Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aefpp4997J (Assessee) (Respondent)

Section 142(1)Section 143(3)Section 144Section 271Section 271(1)(b)Section 274

delay in filing submission should not be constructed strictly, more so when the assessee has co-operated and replied and attended all the hearings. 7. On the other hand, Ld. DR for the Revenue submitted that assessee did not make the compliance of various notices during the assessment proceedings, so penalty should be levied under section 271(1)(b

PRAFULBHAI JAGUBHAI PATEL,SURAT vs. ITO, WARD-1, BARDOLI

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

ITA 1294/SRT/2024[2013-14]Status: DisposedITAT Surat20 May 2025AY 2013-14

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1294/Srt/2024 Assessment Year: (2013-14) (Hybrid Hearing) Prafulbhai Jagubhai Patel, Vs. Ito, 2/7, Dastan, Palsana, Surat – Ward - 1, 394 310 Bardoli "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bvopp8701K (Appellant) (Respondent) Appellant By Shri Shrijignesh Parikh, Ar With Shri Marufkhan Pathan, Ar Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 12/03/2025 Date Of Pronouncement 20/05/2025

Section 144Section 147Section 148Section 148ASection 250Section 69A

B. Bhavaneshwari, (2009) (SC2) GJX 106 (SC), CIT vs. Ram Mohan Kabra, (2002) 257 ITR 773 (P&H) and Surinder Kumar Boveja vs. ITA No.1294/SRT/2024/AY.2013-14 Prafulbhai Jagabhai Patel CWT, (2006) 287 ITR 52 (Del) and held that the appellant had not made a case for having “sufficient cause” for delay in filing appeal. The appeal filed by the appellant

RASHILABEN DHIRAJLAL VORA,SURAT vs. ITO, WARD 3(2)(1), SURAT

In the result, Ground No. 1 of the assessee’s appeal stands allowed for statistical purposes, and the remaining grounds, being consequential and academic at this stage, are not adjudicated upon

ITA 883/SRT/2025[2011-12]Status: HeardITAT Surat07 Oct 2025AY 2011-12

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2011-2012 Rashilaben Dhirajlal Vora, Ito Ward-3(2)(3), 102 Shankheshwar Apartment, Current Jurisdiction Ito Ward Varachha Road, S.O. Bhada, Vs. 3(2)(1), Surat-395006. Aayakar Bhavan, Near Majura Gate, Opp. New Civil Hospital, Surat-395001. Pan No. Aalpv 1275 B Appellant Respondent

For Respondent: Mr. Rasesh Shah, CA
Section 147Section 148Section 249(2)

B Appellant Respondent : Mr. Rasesh Shah, CA Assessee by Revenue by : Mr. J.K. Chandnani, Sr. DR Date of Hearing : 06/10/2025 Date of pronouncement : 07/10/2025 ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against order dated 02.07.2025 passed by the Ld. Commissioner of Income-tax (Appeals) – National Faceless Appeal Centre, Delhi [in short

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

ITA 188/SRT/2025[2015-16]Status: DisposedITAT Surat19 Aug 2025AY 2015-16

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 250Section 271(1)(c)Section 69A

249(2) of the Act. However, it was filed after a delay of more than 17 months. The appellant had not given any sufficient cause for the inordinate delay. But the CIT(A) was very fair and reasonable in condoning the delay and admitting the appeal for adjudication. 10.6 It was alleged by the appellant that the reassessment proceedings were

VIKAS AGARWAL,SILVASSA vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

ITA 191/SRT/2025[2016-17]Status: DisposedITAT Surat19 Aug 2025AY 2016-17

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 250Section 271(1)(c)Section 69A

249(2) of the Act. However, it was filed after a delay of more than 17 months. The appellant had not given any sufficient cause for the inordinate delay. But the CIT(A) was very fair and reasonable in condoning the delay and admitting the appeal for adjudication. 10.6 It was alleged by the appellant that the reassessment proceedings were

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

ITA 192/SRT/2025[2017-18]Status: DisposedITAT Surat19 Aug 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 250Section 271(1)(c)Section 69A

249(2) of the Act. However, it was filed after a delay of more than 17 months. The appellant had not given any sufficient cause for the inordinate delay. But the CIT(A) was very fair and reasonable in condoning the delay and admitting the appeal for adjudication. 10.6 It was alleged by the appellant that the reassessment proceedings were