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ITAT condoned a 450-day delay in filing an appeal, prioritizing substantial justice over technical procedural constraints. The tribunal determined that the delay was not excessive, referencing precedent cases where much longer delays were excused. The decision emphasized that technical limitations should not prevent judicial review when a reasonable cause exists. The tribunal admitted the appeal for adjudication and granted the assessee an opportunity to represent their case before the Assessing Officer, while simultaneously imposing a cost of Rs. 5,000 as a penalty for procedural laxity. The ruling underscores the principle that justice should prevail over strict procedural adherence, particularly when no deliberate misconduct is evident.
ITAT condoned a 450-day delay in filing an appeal, prioritizing substantial justice over technical procedural constraints. The tribunal determined that the delay was not excessive, referencing precedent cases where much longer delays were excused. The decision emphasized that technical limitations should not prevent judicial review when a reasonable cause exists. The tribunal admitted the appeal for adjudication and granted the assessee an opportunity to represent their case before the Assessing Officer, while simultaneously imposing a cost of Rs. 5,000 as a penalty for procedural laxity. The ruling underscores the principle that justice should prevail over strict procedural adherence, particularly when no deliberate misconduct is evident.
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