https://www.taxtmi.com/caselaws?id=311185 ITAT Bangalore dismissed the assessee's appeal challenging CIT(A)'s refusal to condone a 1460-day delay in filing appeal. The assessee claimed they accepted assessment additions believing no penalty would be levied under Section 271(1)(c), but filed appeal only after penalty was imposed. The tribunal held that the assessee's conditional acceptance of additions cannot constitute reasonable cause for delay, as such conditions cannot be imposed on assessment authorities. The decision to not challenge the assessment order until penalty was levied showed no circumstances beyond assessee's control prevented timely filing, making the delay unreasonable and not bona fide. en-us Wed, 22 Mar 2017 00:00:00 +0530 Tue, 12 Dec 2023 20:02:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311185 ITAT Bangalore dismissed the assessee's appeal challenging CIT(A)'s refusal to condone a 1460-day delay in filing appeal. The assessee claimed they accepted assessment additions believing no penalty would be levied under Section 271(1)(c), but filed appeal only after penalty was imposed. The tribunal held that the assessee's conditional acceptance of additions cannot constitute reasonable cause for delay, as such conditions cannot be imposed on assessment authorities. The decision to not challenge the assessment order until penalty was levied showed no circumstances beyond assessee's control prevented timely filing, making the delay unreasonable and not bona fide. Case-Laws Income Tax Wed, 22 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311185