Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
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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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