302-Day Appeal Delay Exceeds Limit; Commissioner (Appeals) Cannot Condone Beyond One Month as Per Law.

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....Condonation of delay of 302 days in filing appeal - It is undisputed that it places a limitation on the extent to which the delay can be condoned by the Commissioner (Appeals). He cannot condone delay of more than one month. There is no provision in this Section for either Tribunal or any other authority to condone the delay in filing appeal before Commissioner (Appeals) in excess of one month. - AT....