2022 (11) TMI 23

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....I, ADVOCATE) RESPONDENT (BY SHRI. M. DILIP ADVOCATE FOR SHRI. K.V. ARAVIND, STANDING COUNSEL) JUDGMENT P.S. DINESH KUMAR J, This appeal by the assessee challenging the order dated 22.03.2017 in ITA No.2281/Bang/2016 has been admitted to consider the following questions of law. "1. Whether the Tribunal was justified in law in not condoning the delay, when the appellant has demo....

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....tly, vide order dated May 05, 2012, penalty has been imposed. 4. Assessee challenged the Assessment Order dated 28.11.2011 before CIT(A) with a delay of 1468 days. The CIT(A) dismissed the appeal on the ground of delay. The ITAT has also dismissed the appeal challenging CIT(A)'s order. 5. Shri. Annamalai for the assessee, submitted that assessee was assured by the Assessing Officer that ....

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....s challenged the same before CIT(A) after 1468 days. The reasons for the delay is stated in para 3 of the Statement of facts filed before CIT(A), which reads as follows: "It was explained to the A.O during the course of hearing to the best of the capacity but, the A.O insisted that he would make the addition and levy penalty and initiate prosecution also and wanted the appellant to accept....