Delay in Appeal Filing: 1950 Days Excluded if Pursuing Wrong Remedy, No Benefit Without Section 154 Petition Filing.

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....Condonation of delay in filing the appeal before the CIT(A) - delay of 1950 days’ in filing the appeal - There is no quarrel on the point if the assessee has chosen a wrong remedy then the time consumed in pursuing the wrong or improper remedy has to be excluded for the purpose of limitation in seeking the proper remedy by way of filing the appeal. But in the absence of filing any petition under section 154, no benefit can be allowed to the assessee merely because the assessee was thinking so. - AT....