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Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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AI Drafter ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether the delay of 263 days in filing the appeal against the demand order ought to be condoned.
Analysis: The appeal had been filed belatedly after the petitioner stated that the show cause notice and demand order were uploaded in the portal and no hard copy was served. The Court accepted this explanation as constituting reasonable cause for the delay and considered the delay to be bona fide rather than wilful or wanton.
Conclusion: The delay of 263 days was condoned, the appellate authority's order rejecting the appeal was set aside, and the appeal was directed to be heard and decided on merits after affording an opportunity of hearing to the petitioner.
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