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A liberal approach governs condonation where refusal would defeat substantial justice, and the death of the authorised representative handling the assessee's tax matters in the faceless regime constituted sufficient cause for the 430-day delay. The Court also held that a jurisdictional objection that reassessment may be void for want of approval under law cannot be excluded by a rigid or hyper-technical limitation analysis. By refusing condonation solely for lack of documentary support and not addressing the pleaded defect, the Tribunal misdirected itself. The delay was condoned, the limitation dismissal was set aside, and the appeal was remanded for fresh adjudication, with the Section 151 validity issue to be decided as a preliminary issue.
A liberal approach governs condonation where refusal would defeat substantial justice, and the death of the authorised representative handling the assessee's tax matters in the faceless regime constituted sufficient cause for the 430-day delay. The Court also held that a jurisdictional objection that reassessment may be void for want of approval under law cannot be excluded by a rigid or hyper-technical limitation analysis. By refusing condonation solely for lack of documentary support and not addressing the pleaded defect, the Tribunal misdirected itself. The delay was condoned, the limitation dismissal was set aside, and the appeal was remanded for fresh adjudication, with the Section 151 validity issue to be decided as a preliminary issue.
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