2021 (2) TMI 349

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....an Alankamony , Member ( A ) This appeal is filed by the assessee against the order of the Ld. CIT(A)-7, Hyderabad in appeal No. 027/CIT(A)-7/2018-19, dated 11-06-2019 passed U/s. 143 (3) r.w.s 147 and U/s. 250(6) of the Act for the A.Y. 2015-16. 2. The assessee has raised five grounds in its appeal and they are extracted herein below for reference:- "1. The appeal is instituted aga....

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....cide the case on question of law as the order of the A.O. is contrary to both law and facts and prejudicial to the interest of justice. 6. The appellant craves to add to/alter/amend/substituted/omit and modify all or any of these grounds. 7. In view of these and other grounds which may be produced during the hearing of appeal the appeal may be allowed and justice rendered." 3.....

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.... the appeal on merits. 5. At the time of hearing, Ld. AR submitted before me that there was a delay of 148 days in filing the appeal before the Ld. CIT(A). Ld. AR further submitted that on 28/05/2018 though the assessee had filed an affidavit before the Ld. CIT(A) and explained the reasons for delay, the Ld. CIT(A) did not consider the assessee's submissions for condonation of delay and dis....

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....e heard the rival submissions and carefully perused the materials on record. On examining the facts of the case, I find merit in the submissions of the Ld. DR. The Ld. CIT(A) had given sufficient opportunities to the assessee to explain the reasons for the delay and furnish evidence for the same. Since, the assessee could not convincingly explain the reasons for delay in filing the appeal, the Ld.....