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    <title>2026 (6) TMI 1336 - ITAT AHMEDABAD</title>
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    <description>Delay in filing the first appellate appeal was condoned on a liberal limitation approach, where the assessee&#039;s bona fide ignorance of the exemption claim and the settled practice in similar BSNL VRS matters were accepted as sufficient cause. On merits, BSNL VRS-2019 compensation was held exempt under the income-tax exemption for voluntary retirement receipts, and the appellate claim was allowed despite not having been raised in the return. The Tribunal also noted that Goetze (India) did not bar relief in appellate proceedings. The Assessing Officer was directed to recompute income and grant consequential refund, if any, in accordance with law.</description>
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      <description>Delay in filing the first appellate appeal was condoned on a liberal limitation approach, where the assessee&#039;s bona fide ignorance of the exemption claim and the settled practice in similar BSNL VRS matters were accepted as sufficient cause. On merits, BSNL VRS-2019 compensation was held exempt under the income-tax exemption for voluntary retirement receipts, and the appellate claim was allowed despite not having been raised in the return. The Tribunal also noted that Goetze (India) did not bar relief in appellate proceedings. The Assessing Officer was directed to recompute income and grant consequential refund, if any, in accordance with law.</description>
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