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    <title>2026 (6) TMI 821 - ITAT DELHI</title>
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    <description>An appeal filed after an extraordinary delay was not entertained because the explanation of lack of knowledge and wrong advice did not cover the full period with sufficient cause; the delay was therefore not condoned and the appeal failed as time-barred. On the merits, a surrendered amount was held to be incapable of being taxed twice where the record indicated it had already been assessed in earlier years; the addition was directed to be deleted, subject to verification of the corresponding earlier assessments. The note states the governing principles that condonation requires a satisfactory explanation for the entire delay and that double addition is impermissible.</description>
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      <link>https://www.taxtmi.com/caselaws?id=793440</link>
      <description>An appeal filed after an extraordinary delay was not entertained because the explanation of lack of knowledge and wrong advice did not cover the full period with sufficient cause; the delay was therefore not condoned and the appeal failed as time-barred. On the merits, a surrendered amount was held to be incapable of being taxed twice where the record indicated it had already been assessed in earlier years; the addition was directed to be deleted, subject to verification of the corresponding earlier assessments. The note states the governing principles that condonation requires a satisfactory explanation for the entire delay and that double addition is impermissible.</description>
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