Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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Inordinate delay in filing the first appeal was not condoned because the assessee failed to show sufficient or bona fide cause. The Tribunal found that the explanation of being unaware of the ex parte assessment was unconvincing, noting the failure to file a return even after notice under section 148 and the non-participation in assessment proceedings, which showed negligence and a lackadaisical approach. Applying the principle that sufficient cause does not extend to inaction, negligence or absence of bona fides, it upheld the CIT(A)'s refusal to exercise discretion under section 249(3) and sustained dismissal of the appeal as time-barred.
Inordinate delay in filing the first appeal was not condoned because the assessee failed to show sufficient or bona fide cause. The Tribunal found that the explanation of being unaware of the ex parte assessment was unconvincing, noting the failure to file a return even after notice under section 148 and the non-participation in assessment proceedings, which showed negligence and a lackadaisical approach. Applying the principle that sufficient cause does not extend to inaction, negligence or absence of bona fides, it upheld the CIT(A)'s refusal to exercise discretion under section 249(3) and sustained dismissal of the appeal as time-barred.
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