2021 (2) TMI 285

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ty) for the assessment year 2013-14. 2. The Revenue has raised the following substantial questions of law for consideration: "1. Whether on facts and in the circumstances of the case, the Tribunal was right holding that filing of manual appeal followed by the e appeal belatedly before the CIT(A) can be condoned and thereby directing the CIT(A) to pass order on merit when the CIT(A) had found that the asssessee had not filed any e appeal? 2. Whether on facts and in the circumstances of the case, the Tribunal was right in condoning the delay in filing of e appeal and thereby directing the CIT(A) to pass order on merit when the CIT(A) had found that the assessee had not filed any e appeal? 3. Whether on facts and in the circumstances ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ld have been solved. Therefore, bearing in mind the fact situation in the year 2016, we are of the view that the appeals need not have been rejected by the CITA on the ground that they were not e-filed within the period of limitation. 13. One more aspect which we had noted is that in the case of assessee in T.C.A.No.433 of 2020, the order of assessment was passed on 31.03.2016, limitation for filing the appeal before the CITA would expire on 30.04.2016 and an appeal filed beyond the said period was time barred. However, if Circular No. 20/2016 is made applicable, then, the time limit for filing the e-appeals stood extended upto 15.06.2016 and even going by the date for verification of eappeals, it was made operational on 12.05.2016 for i....