2024 (8) TMI 547

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..../w Ms. Sabeena Damkhanawala For the Revenue : Shri. Asif Karmali, Sr. DR ORDER PER SUNIL KUMAR SINGH (J.M): 1. This appeal has been preferred against the impugned order dated 22.03.2024 passed in Appeal no. ADDL/JCIT (A) PATNA/10001/2017-18 by the Ld. Commissioner of Income-tax(Appeals) [hereinafter referred to as the "CIT(A)"] u/s. 250 of the Income-tax Act, 1961 [hereinafter referred....

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....nces being beyond the scope of rectification u/s. 154 of the Act was rejected. The appeal before learned CIT(A) could not be filed within the statutory period. The delay was caused by due to assessee's bonafide belief that grievances raised electronically shall be resolved. Prayed to set aside impugned order and provide opportunity of hearing. 3. Learned DR has supported the impugned order. ....

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....riod. Learned CIT(A) was, however not satisfied to condone the said delay of 1638 days. 7. We find that the assessee, submitted its response against the said outstanding demand on the income tax portal on 11.06.2019 & continued pursuing the same till it received the rejection of his prayer for rectification on 01.08.2023. It appears that the assessee was under a bonafide belief that his grievan....

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....o expedite the proceedings before the concerned authorities and to advance the cause of justice. In view of the explanation stated hereinabove, we, deem it just and proper to condone the said delay in filing the first appeal before the first appellate authority. 10. In the result, the appeal is allowed. The impugned order dated 22.03.2024 is set aside. The delay in filing the first appeal befor....