2024 (8) TMI 547

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e 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 to as "Act"] for the Assessment year [A.Y.....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....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. 4. We have heard learned representatives for both....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ndone 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 grievances raised through the income tax portal shall be resol....