Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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The ITAT condoned a delay of 2066 days in filing the appeal, attributing the delay to the assessee's CA's inaction and ongoing FIRs causing a deadlock. The tribunal held that the impugned order was not decided on merits. Consequently, the delay before the CIT(A) was condoned on sufficient cause grounds, but a cost of Rs. 2,500 was imposed on the assessee for lack of vigilance. The impugned order was set aside, and the matter was remanded to the CIT(A) for de novo adjudication. The CIT(A) was directed to provide the assessee a full opportunity of hearing and to pass a reasoned, speaking order after the payment of the imposed cost to the Prime Minister's Relief Fund, with proof of payment to be submitted.
The ITAT condoned a delay of 2066 days in filing the appeal, attributing the delay to the assessee's CA's inaction and ongoing FIRs causing a deadlock. The tribunal held that the impugned order was not decided on merits. Consequently, the delay before the CIT(A) was condoned on sufficient cause grounds, but a cost of Rs. 2,500 was imposed on the assessee for lack of vigilance. The impugned order was set aside, and the matter was remanded to the CIT(A) for de novo adjudication. The CIT(A) was directed to provide the assessee a full opportunity of hearing and to pass a reasoned, speaking order after the payment of the imposed cost to the Prime Minister's Relief Fund, with proof of payment to be submitted.
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