Appeal Filed Late Without Justification; No Leniency Granted, Case Law Deemed Irrelevant.

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....Condonation of delay in filing appeal before the Commissioner (appeals) - since the statutory period specified for filing of appeal (2 months + 1 month) had expired long back in May, 2018 itself and the appeal came to be filed by the petitioner only on 10.01.2022, without substantiating the plea about inability to file appeal within the prescribed time, no indulgence could be shown to the petitioner-assessee at all. The case law in cited by the petitioner is misplaced. - HC....