https://www.taxtmi.com/caselaws?id=755022 The ITAT Hyderabad rejected the assessee's application for condonation of 348 days delay in filing appeal against a revision order under section 263. The assessee claimed delay was due to improper legal advice, but the tribunal found the consultant's advice dated 07/04/2022 clearly outlined two options: challenge the section 263 order or accept it and proceed with revision proceedings. The assessee consciously chose to proceed with revision proceedings before the AO, then later sought to challenge the section 263 order only after realizing limited options in consequential proceedings. The tribunal held this "wait and see" approach did not constitute sufficient cause for delay condonation. en-us Fri, 29 Dec 2023 00:00:00 +0530 Thu, 04 Jul 2024 08:22:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755022 The ITAT Hyderabad rejected the assessee's application for condonation of 348 days delay in filing appeal against a revision order under section 263. The assessee claimed delay was due to improper legal advice, but the tribunal found the consultant's advice dated 07/04/2022 clearly outlined two options: challenge the section 263 order or accept it and proceed with revision proceedings. The assessee consciously chose to proceed with revision proceedings before the AO, then later sought to challenge the section 263 order only after realizing limited options in consequential proceedings. The tribunal held this "wait and see" approach did not constitute sufficient cause for delay condonation. Case-Laws Income Tax Fri, 29 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755022