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Tribunal Upholds Decision: Delay in Filing Cannot Be Condoned Beyond Three Months by Commissioner (Appeals.

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....Condonation of delay in filing appeal - In the present case, Commissioner (Appeals) has not passed any order of confirming any demand against the dead person. The Order was squarely on the ground of limitation. The same has been upheld by this Tribunal only because of the statutory mandate upon the Commissioner (Appeals) to not to condone the delay beyond three months - Application for COD dismissed.....

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