2019 (11) TMI 1442

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.... PER: VIKRAM SINGH YADAV, A.M. These are four appeals filed by the assessee against the respective orders of ld. CIT(A), Ajmer dated 11.05.2017 for the Assessment Years 2013-14, 2014-15 & 2015-16 wherein the assessee has challenged the order of the ld. CIT(A) for not admitting the appeal filed by the assessee and sustaining the penalty levied by the AO U/s 234E of the Act. 2. At the outset, ....

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....able delay beyond the limitation period and accordingly the appeal of the assessee was dismissed and not admitted by the ld. CIT(A). It was submitted that no reasonable cause has been submitted by the assessee for the delay in filing the present appeal. Hence, the condonation application may be rejected and the appeal should be dismissed summarily as barred by limitation. 5. We have heard the r....

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.... thus remain unsubstantiated, we are unable to accede to the request of the assessee for condoning the delay. The delay cannot be condoned merely because the assessee's case calls for sympathy or merely out of benevolence. For the exercise of discretion in condoning the delay, it must be established beyond the shadow of doubt that the assessee was diligent and was not guilty of negligence on i....