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    <title>2025 (6) TMI 1921 - ITAT BANGALORE</title>
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    <description>The Tribunal dismissed the revenue&#039;s appeal as time-barred after rejecting condonation of 100-day delay. The AO cited heavy workload, time-barred assessments, penalty work, and ward mergers as reasons for delay. However, the Tribunal found these generalized explanations insufficient to constitute &quot;sufficient cause&quot; under limitation law. Relying on recent SC precedents, the Tribunal emphasized that government departments cannot rely on bureaucratic inertia or routine workload as justification for delay. The Tribunal held that condonation requires reasonable explanation and bona fide efforts, which were absent. Consequently, the assessee&#039;s cross objection was also dismissed as infructuous.</description>
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      <title>2025 (6) TMI 1921 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=773808</link>
      <description>The Tribunal dismissed the revenue&#039;s appeal as time-barred after rejecting condonation of 100-day delay. The AO cited heavy workload, time-barred assessments, penalty work, and ward mergers as reasons for delay. However, the Tribunal found these generalized explanations insufficient to constitute &quot;sufficient cause&quot; under limitation law. Relying on recent SC precedents, the Tribunal emphasized that government departments cannot rely on bureaucratic inertia or routine workload as justification for delay. The Tribunal held that condonation requires reasonable explanation and bona fide efforts, which were absent. Consequently, the assessee&#039;s cross objection was also dismissed as infructuous.</description>
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