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Appellant's appeal before ITAT is dismissed for non-admission due to inordinate delay of 2,121 days; condonation of delay is refused for want of "sufficient cause" and bona fides. Tribunal found the appeal was prosecuted to exploit process of law after multiple earlier adjudications (AO, CIT(A), Coordinate Bench) concerning alleged bogus purchases where AO had made limited additions and earlier appellate fora rejected genuineness/identity. The Tribunal held equitable pleas of liberal or justice-oriented approach cannot override statutory limitation; public-policy underpinning of limitation bars revival of stale matters. Consequently, appeal is rejected purely on limitation grounds and is not admitted for adjudication.
Appellant's appeal before ITAT is dismissed for non-admission due to inordinate delay of 2,121 days; condonation of delay is refused for want of "sufficient cause" and bona fides. Tribunal found the appeal was prosecuted to exploit process of law after multiple earlier adjudications (AO, CIT(A), Coordinate Bench) concerning alleged bogus purchases where AO had made limited additions and earlier appellate fora rejected genuineness/identity. The Tribunal held equitable pleas of liberal or justice-oriented approach cannot override statutory limitation; public-policy underpinning of limitation bars revival of stale matters. Consequently, appeal is rejected purely on limitation grounds and is not admitted for adjudication.
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