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    <title>2023 (11) TMI 1138 - ITAT KOLKATA</title>
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    <description>The ITAT Kolkata condoned a delay of 1326 days in filing an appeal, finding the delay was caused by the assessee&#039;s former tax consultant&#039;s negligence without malafide intention. The tribunal noted that delay period is less important than explanation quality. Regarding revision under section 263 concerning unexplained cash deposits, the ITAT ruled in favor of the assessee. The tribunal found that the Assessing Officer had conducted detailed enquiry into cash deposits and withdrawals related to a failed land purchase deal, accepted the assessee&#039;s explanations after proper verification, and took a plausible view. Since the assessment was not erroneous, the Principal CIT erred in invoking section 263 jurisdiction.</description>
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      <title>2023 (11) TMI 1138 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=446247</link>
      <description>The ITAT Kolkata condoned a delay of 1326 days in filing an appeal, finding the delay was caused by the assessee&#039;s former tax consultant&#039;s negligence without malafide intention. The tribunal noted that delay period is less important than explanation quality. Regarding revision under section 263 concerning unexplained cash deposits, the ITAT ruled in favor of the assessee. The tribunal found that the Assessing Officer had conducted detailed enquiry into cash deposits and withdrawals related to a failed land purchase deal, accepted the assessee&#039;s explanations after proper verification, and took a plausible view. Since the assessment was not erroneous, the Principal CIT erred in invoking section 263 jurisdiction.</description>
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