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    <title>2026 (7) TMI 391 - ITAT BANGALORE</title>
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    <description>Delay in filing an ITAT appeal may be condoned where the explanation is bona fide and supported by sufficient cause, including reliance on a tax practitioner who failed to act and withheld notices and orders. The Tribunal applied the principle that substantial justice prevails over technical delay and accepted the belated filing. In the property addition dispute, it admitted additional evidence under Rule 29, accepted the assessee&#039;s source trail through bank withdrawals, loan and family agricultural income, and held that an ad hoc attribution of unexplained investment had no basis. It also found that stamp duty value could not be mechanically treated as fair market value on the facts and that the addition had been made under the wrong provision for the relevant year. The additions were deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794505</link>
      <description>Delay in filing an ITAT appeal may be condoned where the explanation is bona fide and supported by sufficient cause, including reliance on a tax practitioner who failed to act and withheld notices and orders. The Tribunal applied the principle that substantial justice prevails over technical delay and accepted the belated filing. In the property addition dispute, it admitted additional evidence under Rule 29, accepted the assessee&#039;s source trail through bank withdrawals, loan and family agricultural income, and held that an ad hoc attribution of unexplained investment had no basis. It also found that stamp duty value could not be mechanically treated as fair market value on the facts and that the addition had been made under the wrong provision for the relevant year. The additions were deleted.</description>
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