2021 (6) TMI 130

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....nst the order of the CIT(A)-3, Hyderabad dated 31.07.2020. At the outset, it is noticed that there is a delay of 153 days in filing of the appeal before the Tribunal. Assessee has filed an application for condonation of delay stating that the delay in filing of the appeal was due to inadvertent mistake and on account of new system of e-assessment proceedings and corona pandemic period. It was thu....

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....t date for filing of the appeal was 01.10.2020, while the assessee filed the appeal on 01.03.2021 all of which dates fall within the period mentioned in the order of the Hon'ble Supreme Court. 2. As regards merits of the case is concerned, assessee has raised the following grounds of appeal. "1. The order of CIT(A)-3 dated 31.7.2020 is contrary to law and facts. 2 The CIT(A) erred in conf....

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..... "5. Having regard to the rival contentions and the material available on record, I find that there is no decision of the Hon'ble Jurisdictional High Court on this issue and out of decisions of Thirteen High Courts, the decisions of ten High Courts are in favour of the assessee while the decisions of three High Courts are against the assessee In some of the other High Courts, the issue has ....