Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
The ITAT considered the condonation of delay in filing appeals before the CIT(A). The delay of 93 days was attributed to pursuing alternative remedies in the High Court. The ITAT held that the delay was reasonable and not willful, supported by legal precedent. The ITAT emphasized that the cause for delay is crucial, not just the duration. Citing a case where a 21-year delay was condoned, the ITAT found the 93-day delay acceptable. The delay was condoned u/s 253(5) of the Act. Regarding ex-parte assessment orders, the ITAT referred to a High Court decision criticizing the AO's failure to consider the assessee's submissions. The matter was remitted back to the AO for reconsideration, emphasizing adherence to principles of natural justice.
The ITAT considered the condonation of delay in filing appeals before the CIT(A). The delay of 93 days was attributed to pursuing alternative remedies in the High Court. The ITAT held that the delay was reasonable and not willful, supported by legal precedent. The ITAT emphasized that the cause for delay is crucial, not just the duration. Citing a case where a 21-year delay was condoned, the ITAT found the 93-day delay acceptable. The delay was condoned u/s 253(5) of the Act. Regarding ex-parte assessment orders, the ITAT referred to a High Court decision criticizing the AO's failure to consider the assessee's submissions. The matter was remitted back to the AO for reconsideration, emphasizing adherence to principles of natural justice.
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