2024 (5) TMI 146

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....decision of ld. CIT(A) in dismissing the appeal of the assessee in-limine without condoning the delay in filing the appeal before him. 2. The ld. A.R submitted that the assessee along with some other persons had purchased a property on 31-12-2011, wherein the share of the assessee was only 20%. The cost of the property was Rs. 6.16 crores while the stamp duty value was Rs. 6.18 crores. The assessee had paid only a sum of Rs. 40.00 lakhs during the year under consideration. The assessee did not file any return of income for this year. Based on the information about the purchase of property, the Assessing Officer reopened the assessment of the instant year u/s. 147 of the Act. However, the Assessing Officer has served all the notices to th....

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.... the facts mentioned above. However, the Ld CIT(A) has computed the delay as 783 days and accordingly dismissed the appeal of the assessee in-limine without condoning the delay. 4. The ld.AR reiterated that the assessee came to know about the assessment order only on 20/03/2023 and the said date should be reckoned as date of service of the assessment order. Further, the time limit was extended by the Hon'ble Supreme Court of India due to COVID -19 pandemic till May, 2022. Accordingly, the ld.A.R submitted that there was no delay in filing of the appeal before the ld.CIT(A). The Ld A.R further submitted that the order passed by Ld CIT(A) should be set aside. 5. The ld A.R further submitted that the Ld CIT(A) has not passed the order on....