https://www.taxtmi.com/caselaws?id=211026 The Tribunal condoned the 788-day delay in filing the appeal, emphasizing the absence of willful negligence. Regarding the jurisdiction under section 263 of the Act, the Tribunal found that the ld. C.I.T. did not point out any irregularity in the accounts and failed to provide a reasonable opportunity for explanation. As a result, the Tribunal sent the matter back to the ld. C.I.T. for fresh adjudication, stressing the importance of procedural fairness. The appeal was allowed for statistical purposes, underscoring the necessity of providing adequate opportunities for parties to present their case effectively. en-us Fri, 06 Jan 2012 00:00:00 +0530 Thu, 01 Mar 2012 09:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211026 The Tribunal condoned the 788-day delay in filing the appeal, emphasizing the absence of willful negligence. Regarding the jurisdiction under section 263 of the Act, the Tribunal found that the ld. C.I.T. did not point out any irregularity in the accounts and failed to provide a reasonable opportunity for explanation. As a result, the Tribunal sent the matter back to the ld. C.I.T. for fresh adjudication, stressing the importance of procedural fairness. The appeal was allowed for statistical purposes, underscoring the necessity of providing adequate opportunities for parties to present their case effectively. Case-Laws Income Tax Fri, 06 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211026