BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

129 results for “condonation of delay”+ Section 271clear

Sorted by relevance

Mumbai444Delhi343Chennai220Ahmedabad199Jaipur191Kolkata140Bangalore135Pune133Surat129Hyderabad120Indore98Rajkot66Nagpur53Lucknow51Chandigarh51Cochin37Cuttack34Visakhapatnam33Patna33Guwahati26Agra26Amritsar23Ranchi23Raipur21Panaji13Jabalpur12SC12Allahabad10Dehradun6Jodhpur5Varanasi2

Key Topics

Section 271(1)(b)179Section 142(1)103Section 271(1)(c)95Penalty88Section 143(3)79Addition to Income71Section 14451Section 153A42Section 254(1)

BASANT SEKHANI,SURAT vs. INCOME TAX OFFICER WARD 2(2)(1), SURAT

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

ITA 585/SRT/2023[2010-11]Status: HeardITAT Surat01 Nov 2023AY 2010-11

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 144Section 254(1)Section 271(1)(b)Section 271(1)(c)Section 69

condoned the delay, resultantly the appeal was not admitted and dismissed in limine. Similarly, there was a delay in filing appeal in penalty proceedings under Section 271

BASANT SEKHANI,SURAT vs. INCOME TAX OFFICER WARD 2(2)(1), SURAT

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

Showing 1–20 of 129 · Page 1 of 7

40
Section 25039
Limitation/Time-bar24
Search & Seizure22
ITA 584/SRT/2023[2010-11]Status: HeardITAT Surat01 Nov 2023AY 2010-11

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 144Section 254(1)Section 271(1)(b)Section 271(1)(c)Section 69

condoned the delay, resultantly the appeal was not admitted and dismissed in limine. Similarly, there was a delay in filing appeal in penalty proceedings under Section 271

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)

Section 249(2) of the IT Act, 1961. 4.The Chartered Accountant at Surat was also not having any experience or exposure in attending appeal before CIT(A) therefore said Chartered Accountant has not filed any Miscellaneous Application or Affidavit for Condonation of Delay and such miscellaneous application and affidavit is being filed before Hon'ble Surat for the first time

PINKY MANISHKUMAR JARIWALA,SURAT vs. INCOME TAX OFFICER, WARD-2(2)(3), SURAT

In the result, the appeal filed by assessee, in ITA No

ITA 281/SRT/2022[2009-10]Status: DisposedITAT Surat28 Aug 2023AY 2009-10

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita Nos.280 To 282/Srt/2022 Assessment Years: (2009-10) (Physical Hearing) Pinky Manishkumar Jariwala, Vs. The Ito, 4/1710, Nawabwadi, Begampura, Ward – 2(2)(3), Surat – 395003. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahnpj7591D (Appellant) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Shri Vinod Kumar, Sr. Dr Respondent By Date Of Hearing 23/08/2023 Date Of Pronouncement 28/08/2023

Section 144Section 147Section 148Section 271(1)(c)

section 144 r.w.s. 147 of the Act, and two penalty orders passed by Assessing Officer u/s 271(1)(c) and 271(1)(b) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). 2. These three appeals filed by the assessee for Assessment Year 2009-10, are barred by limitation by one day. The assessee has moved

PINKY MANISHKUMAR JARIWALA,SURAT vs. INCOME TAX OFFICER, WARD-2(2)(3), SURAT

In the result, the appeal filed by assessee, in ITA No

ITA 282/SRT/2022[2009-10]Status: DisposedITAT Surat28 Aug 2023AY 2009-10

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita Nos.280 To 282/Srt/2022 Assessment Years: (2009-10) (Physical Hearing) Pinky Manishkumar Jariwala, Vs. The Ito, 4/1710, Nawabwadi, Begampura, Ward – 2(2)(3), Surat – 395003. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahnpj7591D (Appellant) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Shri Vinod Kumar, Sr. Dr Respondent By Date Of Hearing 23/08/2023 Date Of Pronouncement 28/08/2023

Section 144Section 147Section 148Section 271(1)(c)

section 144 r.w.s. 147 of the Act, and two penalty orders passed by Assessing Officer u/s 271(1)(c) and 271(1)(b) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). 2. These three appeals filed by the assessee for Assessment Year 2009-10, are barred by limitation by one day. The assessee has moved

PINKY MANISHKUMAR JARIWALA,SURAT vs. INCOME TAX OFFICER, WARD-2(2)(3), SURAT

In the result, the appeal filed by assessee, in ITA No

ITA 280/SRT/2022[2009-10]Status: DisposedITAT Surat28 Aug 2023AY 2009-10

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita Nos.280 To 282/Srt/2022 Assessment Years: (2009-10) (Physical Hearing) Pinky Manishkumar Jariwala, Vs. The Ito, 4/1710, Nawabwadi, Begampura, Ward – 2(2)(3), Surat – 395003. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahnpj7591D (Appellant) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Shri Vinod Kumar, Sr. Dr Respondent By Date Of Hearing 23/08/2023 Date Of Pronouncement 28/08/2023

Section 144Section 147Section 148Section 271(1)(c)

section 144 r.w.s. 147 of the Act, and two penalty orders passed by Assessing Officer u/s 271(1)(c) and 271(1)(b) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). 2. These three appeals filed by the assessee for Assessment Year 2009-10, are barred by limitation by one day. The assessee has moved

RAGHUNANDAN IMPEX PVT LTD,SURAT vs. INCOME TAX OFFICER, WD-2(1)(1), SURAT, SURAT

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 641/SRT/2025[2012-13]Status: DisposedITAT Surat30 Oct 2025AY 2012-13

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-2013 Raghunandan Impex Pvt. Ltd., Ito Ward 2(1)(1), 6/2037, Office No. 205, 2Nd Floor, Room No. 222, Papadwala Building, Bhoja Bhai Vs. Aayakar Bhavan, Ni Sheri, Mahidharpura, Majura Gate, Surat-395003. Surat-395001. Pan No. Aaecr 5688 Q Appellant Respondent

For Appellant: Mr. Prakash Jhunjhunwala, CAFor Respondent: Mr. J.K. Chandnani, Sr. DR
Section 271Section 271(1)(c)Section 68

condone the delay of 490 days in the filing of the appeal. of 490 days in the filing of the appeal. 4. Proceeding to the next issue, the Proceeding to the next issue, the Ld. Counsel for the Ld. Counsel for the assessee submitted that the appeal against the quantum submitted that the appeal against the quantum submitted that

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

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 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 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 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

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

SANTOSH SINGH HUKAM SINGH KARNAWAT,SURAT vs. ITO, WARD 2(3)(8), SURAT

In the result, the appeal filed by the assessee is allowed

ITA 655/SRT/2025[2012-13]Status: DisposedITAT Surat25 Nov 2025AY 2012-13

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri Rasesh Shah, CAFor Respondent: Shri Ajay Uke, Sr. DR
Section 133(6)Section 250Section 271(1)(c)

section 271(1)(c) is liable to be deleted, and the appeal of the assessee is allowed. 19. Further, the delay of 40 days in filing the present appeal is condoned

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 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 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 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

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