TaxTMI 
TaxTMI 
2020 (4) TMI 849
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....A] has not taken in to account that appellant has filed first appeal against order u/s 147 read with 143[3] during course of hearing of that appeal appellant has realized that appeal against the original order u/ s 143[3] has to be filed hence it was delay. 3. CIT[A] has not taken into account the order u/s 154 is passed after order under u/ s 143[3] r.w. 147 is passed. appellant has already filed appeal against the order u/ s 143[3] r.w. 147 . 4. CIT[A] has not taken into account that AO has disallowed u/s 14A Rs. 159931/ - against the exempted income claimed by the assessee Rs. 1942/ - disallowance cannot be more than exempted income hence Appellant has applied for rectification order under section 154 is passed after passing of order....
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....ation the appeal is filed belatedly. Resultantly, the delay was not condoned and appeal was not admitted for hearing. Further aggrieved, the assessee has filed the present appeal before us. 3. None appeared on behalf of assessee nor is application for adjournment was filed. Perusal of record reveals that assessee has filed written submission on record. In the written submission, the assessee stated that there was sufficient cause for condoning the delay as delay was not intentional or due to negligent. During the course of hearing in appeal filed by assessee against the order under section 143(3) r.w.s 147 and the order under section 154. The assessee realized of filing the delay against both the orders. The assessee prayed for condonation....