https://www.taxtmi.com/caselaws?id=790787 Limitation should not be applied rigidly where the explanation shows a bona fide impediment; the death of the assessee's authorised representative and the shift to a faceless regime were treated as sufficient cause for condoning a 430-day delay in filing the appeal. A challenge to reassessment for lack of proper approval under Section 151 was treated as a jurisdictional objection going to the root of the proceeding, and it had to be decided as a preliminary issue before other matters. The impugned order was set aside, the delay was condoned, and the matter was remitted for fresh adjudication with jurisdiction to be determined first. en-us Tue, 28 Apr 2026 00:00:00 +0530 Thu, 30 Apr 2026 07:19:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790787 Limitation should not be applied rigidly where the explanation shows a bona fide impediment; the death of the assessee's authorised representative and the shift to a faceless regime were treated as sufficient cause for condoning a 430-day delay in filing the appeal. A challenge to reassessment for lack of proper approval under Section 151 was treated as a jurisdictional objection going to the root of the proceeding, and it had to be decided as a preliminary issue before other matters. The impugned order was set aside, the delay was condoned, and the matter was remitted for fresh adjudication with jurisdiction to be determined first. Case-Laws Income Tax Tue, 28 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790787