https://www.taxtmi.com/caselaws?id=792124 An 850-day delay in filing the first appeal was condoned because the assessee explained that the order had remained with an accountant who left without informing the partners, and the record showed the related quantum dispute was already in appellate litigation, including before the Supreme Court; the delay was therefore treated as not mala fide and was excused in the interest of substantial justice. Penalty under section 271(1)(c) was deleted because the disallowance linked to deduction under section 80IB(10) involved a debatable issue on which judicial views had differed, so adopting one possible view did not by itself establish concealment or furnishing of inaccurate particulars. en-us Wed, 22 Apr 2026 00:00:00 +0530 Sat, 23 May 2026 08:27:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792124 An 850-day delay in filing the first appeal was condoned because the assessee explained that the order had remained with an accountant who left without informing the partners, and the record showed the related quantum dispute was already in appellate litigation, including before the Supreme Court; the delay was therefore treated as not mala fide and was excused in the interest of substantial justice. Penalty under section 271(1)(c) was deleted because the disallowance linked to deduction under section 80IB(10) involved a debatable issue on which judicial views had differed, so adopting one possible view did not by itself establish concealment or furnishing of inaccurate particulars. Case-Laws Income Tax Wed, 22 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792124