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Delay in filing an appeal before CIT(A) - assessee was pursuing the matter at wrong forum - It can be appreciated that the Assessee’s claim is primarily is of wrong advice in choosing the forum under law to contest the assessment order - The stringent laws of limitation require liberal interpretation. In the case in hand apparently the ld CIT(A) has not gone at all into discussing the grounds which were submitted and with the cursory observations the appeal has been dismissed barred by limitation - Delay condoned - AT
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