https://www.taxtmi.com/caselaws?id=764845 ITAT Agra remanded matter to CIT(A) after assessee filed appeal 2176 days late challenging MMR applicability versus normal taxation rates. Assessee claimed unawareness of return processing under section 143(1) until receiving demand notice, while Revenue argued intimation was uploaded on IT e-portal constituting deemed service. CIT(A) dismissed appeal solely on delay grounds without investigating service method. ITAT held CIT(A) must enquire into actual service compliance with section 282 and Rule 127, citing precedent that mere e-portal uploading insufficient for proper service under natural justice principles. Matter restored to CIT(A) for fresh consideration of delay condonation application. en-us Fri, 17 Jan 2025 00:00:00 +0530 Mon, 20 Jan 2025 08:10:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764845 ITAT Agra remanded matter to CIT(A) after assessee filed appeal 2176 days late challenging MMR applicability versus normal taxation rates. Assessee claimed unawareness of return processing under section 143(1) until receiving demand notice, while Revenue argued intimation was uploaded on IT e-portal constituting deemed service. CIT(A) dismissed appeal solely on delay grounds without investigating service method. ITAT held CIT(A) must enquire into actual service compliance with section 282 and Rule 127, citing precedent that mere e-portal uploading insufficient for proper service under natural justice principles. Matter restored to CIT(A) for fresh consideration of delay condonation application. Case-Laws Income Tax Fri, 17 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764845