2022 (2) TMI 1308

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....er pronounced on 7th April 2017 passed by the Income Tax Appellate Tribunal (ITAT), rejecting the application for condonation of delay in filing the appeals filed by appellant relating to penalty order dated 3rd March 2005 under Section 271(1)(c) of the Income Tax Act 1961 (the Act), in three appeals filed for A.Y.-1999-2000, 2001- 2002 and 2002-2003. According to ITAT, the assessee has filed its ....

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...., appellant decided to challenge the penalty orders. The challenge was rejected by CIT(A) saying that the appeals have been filed with much delay. CIT(A) overlooked one factor that the prosecution itself has been launched 8 or 9 years after the penalty amount was paid by appellant. If the department feels that they can do this after 8 or 9 years delay, in our view, they must apply the same yardsti....