https://www.taxtmi.com/caselaws?id=252873 The Tribunal allowed both appeals of the assessee. The delay in filing the appeal was condoned as the Tribunal found the delay was due to mistaken advice. The order passed under Section 263 was deemed bad in law as the AO had already considered the issue, and the CIT's order was held to be without jurisdiction. The penalty order under Section 271(1)(c) was quashed as it was based on the order under Section 263, which was also set aside. The Tribunal emphasized a justice-oriented approach and the importance of considering the merits of the case. en-us Wed, 15 Oct 2014 00:00:00 +0530 Thu, 06 Nov 2014 05:53:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252873 The Tribunal allowed both appeals of the assessee. The delay in filing the appeal was condoned as the Tribunal found the delay was due to mistaken advice. The order passed under Section 263 was deemed bad in law as the AO had already considered the issue, and the CIT's order was held to be without jurisdiction. The penalty order under Section 271(1)(c) was quashed as it was based on the order under Section 263, which was also set aside. The Tribunal emphasized a justice-oriented approach and the importance of considering the merits of the case. Case-Laws Income Tax Wed, 15 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252873