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of HC held that CIT(A)'s power under Sec 251(2) requires deciding appeals on merits after providing reasonable opportunity. Delay in filing appeal was partially attributed to COVID-19 pandemic, warranting condonation under Limitation Act Sec 5. Court found no mala fide intent in delayed filing, noting that litigants generally don't benefit from belated appeals. Given the significance of tax liability and CIT(A)'s coterminous powers with assessing officer, appeal was restored for merit-based determination, conditional upon appellant's cooperation and no adjournment requests. Tribunal's order and CIT(A)'s order dated 16.10.2019 were set aside.
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