https://www.taxtmi.com/caselaws?id=754801 ITAT Surat condoned 1100-day delay in filing appeal against order u/s 263, finding sufficient cause where income tax practitioner erroneously believed the order was not appealable. The tribunal applied liberal construction of "sufficient cause" principle, noting lawyer's mistake constitutes valid grounds for condonation when no negligence or bad faith exists. The PCIT's ex-parte order u/s 263 was set aside for violating natural justice principles as assessee lacked adequate hearing opportunity. Matter remitted to PCIT for fresh adjudication on merits. Appeal treated as allowed for statistical purposes. en-us Mon, 22 Jan 2024 00:00:00 +0530 Sat, 29 Jun 2024 12:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754801 ITAT Surat condoned 1100-day delay in filing appeal against order u/s 263, finding sufficient cause where income tax practitioner erroneously believed the order was not appealable. The tribunal applied liberal construction of "sufficient cause" principle, noting lawyer's mistake constitutes valid grounds for condonation when no negligence or bad faith exists. The PCIT's ex-parte order u/s 263 was set aside for violating natural justice principles as assessee lacked adequate hearing opportunity. Matter remitted to PCIT for fresh adjudication on merits. Appeal treated as allowed for statistical purposes. Case-Laws Income Tax Mon, 22 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754801