Court condones 421-day delay in appeals challenging assessment order. Tribunal upholds CIT(A)'s decision.

The court condoned the substantial delay of 421 days in re-filing appeals concerning Assessment Years 2007-08 and 2008-09. The appeals challenged a common order regarding various additions made during assessment proceedings. The CIT(A) set aside the assessment order due to jurisdictional errors and lack of tangible material. The Tribunal upheld this decision, dismissing the appeal of the appellant/revenue. The court found no substantial question of law, concluding that the findings of the Tribunal and CIT(A) were not perverse, and closed the appeals accordingly.

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Issues:
The judgment involves applications seeking condonation of delay in re-filing appeals, and appeals concerning Assessment Years (AYs) 2007-08 and 2008-09.

Delay Condonation:
The appellant/revenue sought condonation of delay of 421 days in re-filing the appeals. Despite the substantial delay, the court decided to hear the matter on merits and condoned the delay.

Assessment Years 2007-08 and 2008-09:
The appeals challenged a common order dated 22.03.2021 concerning AYs 2007-08 and 2008-09. The issues arising in these years were found to be common. The assessment proceedings revealed additions made on various grounds, including unexplained share application money and other deposits. The CIT(A) set aside the assessment order on grounds related to jurisdictional errors and lack of tangible material. The Tribunal upheld the CIT(A)'s findings, dismissing the appeal of the appellant/revenue.

Grounds and Findings:
The appellant/revenue raised grounds related to the absence of a notice under Section 143(2) and the jurisdictional error in issuing the assessment order. The CIT(A) findings on communication with the AO regarding the return filed were upheld by the Tribunal. The appellant/revenue did not challenge the conclusions on the sanctioning authority's independent appraisal. The court found no substantial question of law and closed the appeals, noting that the findings of fact by the Tribunal and CIT(A) were not perverse.

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