Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
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ITAT dismissed the assessee's appeal as time-barred, refusing to condone an inordinate delay of 562 days in filing. The assessee's explanation that the delay was due to a period of custody was rejected, as custody ended long before the impugned CIT(A) order and the filing of appeal, and multiple hearing notices were duly issued to the assessee and its authorised representative. ITAT held that no sufficient cause was shown for condonation under settled law. Though the Tribunal noted that the penalty notices under s. 271(1)(c) were defective for not specifying a clear charge, the appeal itself was not entertained on account of the unexplained delay.
ITAT dismissed the assessee's appeal as time-barred, refusing to condone an inordinate delay of 562 days in filing. The assessee's explanation that the delay was due to a period of custody was rejected, as custody ended long before the impugned CIT(A) order and the filing of appeal, and multiple hearing notices were duly issued to the assessee and its authorised representative. ITAT held that no sufficient cause was shown for condonation under settled law. Though the Tribunal noted that the penalty notices under s. 271(1)(c) were defective for not specifying a clear charge, the appeal itself was not entertained on account of the unexplained delay.
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