2016 (10) TMI 1392

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....als) Palampur dated 28.07.2016 for assessment year 2007-08. 2. The assessee challenged the order under section 154 of the Act and addition of Rs. 3,76,202/- before ld. CIT(Appeals). The written submission of the assessee on merit has also been reproduced in the impugned order. The ld. CIT(Appeals), instead of considering the submissions of the assessee found that appeal of the assessee is late by....

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....-consideration at the level of the ld. CIT(Appeals). The ld. CIT(Appeals) noted the facts of the case and written submission of the assessee in the impugned order but did not pass any order on merit. He has held that appeal is time barred by 26 days and in absence of application for condonation of delay, appeal was dismissed. There is no fact mentioned in the impugned order if any opportunity was ....