Assessee's appeal dismissed for 206-day delay without condonation application or reasonable explanation

ITAT Raipur dismissed the appeal due to a 206-day delay in filing without any condonation application. The assessee failed to provide explanations for the substantial delay and adopted a negligent approach. The tribunal emphasized that limitation laws must be construed strictly as they affect parties' rights, and delays cannot be condoned mechanically. The expression "sufficient cause" requires reasonableness and conduct within normal human behavior. The tribunal deprecated the assessee's lackadaisical conduct and refused to adopt a liberal view given the absence of any condonation application or reasonable explanation for the delay.

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Issues involved:
The issues involved in the judgment are the addition of unexplained cash deposited during demonetization period, application of Section 115BBE, delay in filing the appeal, and condonation of the delay.

Addition of unexplained cash:
The assessee failed to substantiate the source of cash deposits made during demonetization period, leading to the addition of Rs. 14,90,000 as unexplained cash under Sec. 69A of the Income-tax Act, 1961. The Assessing Officer (A.O) assessed the income of the assessee at Rs. 19,51,600 based on this unexplained money.

Application of Section 115BBE:
The assessee challenged the application of Section 115BBE by the Commissioner of Income-Tax (Appeals) in the case. The grounds of appeal included disputing the application of this section.

Delay in filing the appeal:
The present appeal involved a delay of 206 days, and the assessee did not file any application seeking condonation of the delay. The Authorized Representative for the assessee failed to rebut the lack of application for condonation.

Condonation of the delay:
The Tribunal considered the lackadaisical approach of the assessee in not filing the appeal within the stipulated time period. Citing previous judgments, the Tribunal emphasized the need for a bonafide application for condonation of delay. Since the assessee did not provide any explanation for the substantial delay, the Tribunal declined to condone the delay and dismissed the appeal as barred by limitation.

Conclusion:
The Tribunal dismissed the appeal of the assessee due to the substantial delay in filing the appeal and the lack of application for condonation. The decision was made without delving into the merits of the case, emphasizing the importance of adhering to the time limits set by law.

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