Late tax return filing results in penalty appeal & delay condonation for fair hearing.

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....Penalty imposed u/s 271B for delay in filing the return. The key points are: The assessee failed to get accounts audited as per Section 44AB. The penalty order u/s 271B was passed on 05.07.2021, and the assessee filed an appeal before the CIT(A)/NFAC on 22.01.2022, resulting in a delay of 171 days. Following the Tribunal's order in the assessee's quantum proceedings for the same assessment year, the issue was restored to the CIT(A)/NFAC to condone the delay in filing the appeal and decide the matter on merits after providing an opportunity of being heard to the assessee. The grounds raised by the assessee were allowed for statistical purposes.....