2025 (2) TMI 230

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.... J.M. : This appeal has been filed by the assessee against the order dated 18.09.2024 of the learned Addl/JCIT(A)-2, Jaipur, relating to assessment year 2020-2021. 2. Facts of the case, in brief, are that the assessee is an individual and derives income from salary, income under the head PGBP from trading in futures and options, interest income from interest on income tax return. The assessee ha....

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....ation filed u/sec.154 of the Act was rejected by the department on 31.07.2024. Thereafter, the assessee carried the matter in appeal before the learned CIT(A) with a delay of about 07 months by filing condonation of delay petition and affidavit. The learned CIT(A) did not satisfy with the reasons furnished by the assessee for the said delay of about 07 months and dismissed the appeal of the assess....

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....rectification proceedings u/sec.154 and appellate proceedings u/sec.250(A) of the Act before the learned CIT(A) are two different proceedings. Therefore, the learned CIT(A) has rightly dismissed the appeal of assessee as per the provisions of the income Tax Act, 1961 and pleaded that the order of the learned CIT(A) be upheld. 6. I have heard rival submissions of both the parties, perused the orde....

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....n a meritorious matter being thrown-out at the very threshold and cause of justice being defeated. As against this, when delay is condoned, the highest that can happen is that a cause would be decided on merits after hearing the parties. In view of the above decision of Hon'ble Supreme Court in the case of Collector, Land Acquisition vs., MST Katiji (supra) and considering the submission of the as....