2022 (5) TMI 732

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....R.V. Sreenivasan, Addl.CIT ORDER PER MAHAVIR SINGH , VP: This appeal by the assessee is arising out of the revision order of Principal Commissioner of Income Tax - 3, Chennai in C.No.3033(4)/PCIT-3/2018-19, order dated 28.03.2019 passed u/s.263 of the Income Tax Act, 1961 (hereinafter the 'Act') . 2. At the outset it is noticed that this appeal came up for hearing for the first time on....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ssee's legal consultant stated that intimation is factually incorrect and application for rectification u/s.154 of the Act shall be filed. The assessee has stated the following reasons in the affidavit:- "1) I, Manual Anand David aged about 50 years, son of David identified by PAN AGXPD9534D at present residing at Address C-11, Venkataraman Road, Periyar Nagar, Chennai - 600082 do solemnl....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ion of delay as provided under section 5 of the Limitation Act, 1963. 6) That in this way there is a delay of 95 days for which an application under Section 5 of the Limitation Act has been filed along with memorandum of appeal. 7) That delay in filing the appeal is because of a genuine belief of the applicability of a particular provision of the Income Tax Act 1962 which was not....