2021 (4) TMI 194

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....nst the assessment order u/s 144 read with section 143(3) of the Act (for short 'the Act') and vide second order the Ld. CIT(A) has dismissed the appeal file by the assessee against the penalty order passed by the Assessing Officer u/s 271(1)(c) of the Act. 2. The ld. Counsel for the assessee submitted before us that the assessee wants to opt for Vivad Se Viswas Scheme, 2020, however, since there is a delay in filing of these appeals and as per Circular No. 21/2020 dated 4.12. 2020 issued by the CBDT, the assessee will be eligible in such cases if the competent authority condones the delay in filing the appeals. 3. The Ld. counsel further submitted that there is a delay of 1189 days in filing the appeal against quantum order passed by the....

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....he assessee has failed to prove sufficient cause for condonation of such delay. However, the ld. DR further submitted that since the assessee wants to opt for Vivad Se Vishwas Scheme 2020, a lenient view may be taken and the appeals may be decided accordingly. 5. We have heard the submissions made by both the sides and perused the material on record. As pointed out by the ld. Counsel, since the assessee had closed its business operations the assessee could not receive the order passed by the Ld. CIT(A). The department has not rebutted these fats. Further, the assessee could not file the appeals within limitation period as the partner of the assessee had to undergo medical treatment due to his ill health. 6. The Hon'ble Supreme Court i....