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    <title>2025 (11) TMI 2027 - ITAT MUMBAI</title>
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    <description>Delay in filing the first appeal against an intimation was attributable to the assessee not noticing electronic communications during the Covid-19 lockdown, when office operations and staff movement were severely disrupted. An affidavit and prompt action after discovery of the demand through refund adjustment supported the assessee&#039;s bona fides. Pandemic-related exclusion of limitation for judicial and quasi-judicial proceedings materially reduced the delay, and the remaining period was reasonably explained. Applying the liberal approach to limitation where sufficient cause exists, the delay was condoned and the matter was restored to the appellate authority for adjudication of additions and exemption denial on merits.</description>
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      <link>https://www.taxtmi.com/caselaws?id=470030</link>
      <description>Delay in filing the first appeal against an intimation was attributable to the assessee not noticing electronic communications during the Covid-19 lockdown, when office operations and staff movement were severely disrupted. An affidavit and prompt action after discovery of the demand through refund adjustment supported the assessee&#039;s bona fides. Pandemic-related exclusion of limitation for judicial and quasi-judicial proceedings materially reduced the delay, and the remaining period was reasonably explained. Applying the liberal approach to limitation where sufficient cause exists, the delay was condoned and the matter was restored to the appellate authority for adjudication of additions and exemption denial on merits.</description>
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