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    <description>Delay in filing the appeal was condoned because the appellant acted under a bona fide belief that the earlier appeal before the Commissioner (Appeals) was still pending, and no opportunity had been given to explain the delay. Since the Commissioner (Appeals) had rejected the matter only on limitation without examining the merits, the case was found fit for reconsideration. The appeal was remanded to the Commissioner (Appeals) for fresh decision on merits after granting the appellant an opportunity to be heard.</description>
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      <description>Delay in filing the appeal was condoned because the appellant acted under a bona fide belief that the earlier appeal before the Commissioner (Appeals) was still pending, and no opportunity had been given to explain the delay. Since the Commissioner (Appeals) had rejected the matter only on limitation without examining the merits, the case was found fit for reconsideration. The appeal was remanded to the Commissioner (Appeals) for fresh decision on merits after granting the appellant an opportunity to be heard.</description>
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