2021 (10) TMI 1242

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..../2019-2020 and 10097/2019-2020; respectively in proceedings under Section 143(3) r.w.s. 153C of Income Tax Act, 1961 ('the Act'). Heard both the parties. Case file perused. 2. We notice at the outset that all the four Revenue's instant appeals suffer from 9 days delay in filing. Learned department representative submitted that due to the outbreak of pandemic covid 19 unable to get the documents from the department which caused the impugned delay in filing of the instant appeal. Case law Collector Land Acquisition Vs. Mst. Katiji & Ors, 1987 AIR 1353 (SC) and University of Delhi Vs. Union of India, Civil Appeal No. 9488 & 9489/2019 dated 17th Dec., 2019, hold that such a delay; supported by cogent reasons, deserves to be co....

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....ucted at the premises of MBS Jewellers Pvt. Ltd. and others. Consequent to that, assessments in the case of appellant was completed and passed by the A.O. u/s. 143(3) r.w.s. 153C dt. 30.12.2011. In connection to these it is submitted that the Hon'ble ITAT in one of the group cases of the appellant, namely P.S. Prasad for A.Y. 2006-07 vide its order dt. 09.12.2015 having ITA No. 1211/H/2014 (para No. 4) has quashed the order on account of non-satisfaction u/s. 153C of the Act and has allowed the appeal of the assessee." We find no substance in Revenue's foregoing sole substantive grievance. This tribunal's co-ordinate bench common order in Mr. S. Satyanarayana & Others dt. 9.12.2015 involving a batch of appeals pertai....