Court Evaluates 439-Day Delay in Appeal Filing Due to Improper Advice u/s 263; Considers Justice and Diligence.

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....Condonation of delay of 439 days - sufficient cause - lack of proper advice - appeal filed against assessment order before the CIT (A) within time but no Challenge of order of CIT passed u/s 263 - it was not a total lack of diligence on the part of the assessee - The sufficiency of the cause shown by the appellant is a matter to be weighed on the scales of justice....