2025 (5) TMI 1313

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..... 2. At the outset, it is observed that there has been a delay of 536 days in filing the appeal by the assessee before the Tribunal. In this regard, the assessee has submitted an affidavit explaining the reasons for the delay. 2.1 It was explained that the appeal against the assessment order was originally filed in physical form on 18 January 2017. Later, due to Notification No. 76 of 2020 S.O. 3296 (E) dated 25 September 2020, the appeal was migrated to the National Faceless Appeal Centre (NFAC). Thereafter, the NFAC issued multiple notices on different dates to the assessee, informing him about the hearing dates. However, all such notices were issued during the COVID-19 period, except for one notice dated 1 March 2023. 2.2 The as....

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....tedly significant. However, upon analyzing the reasons cited for the delay, we observe that the employee whose email ID was used in Form 35 had left the assessee's organization. Due to this, the assessee was unaware of the order passed by the learned CIT(A). This point raised by the AR was not disputed by the ld. DR. 5. Considering the above reason, we find that there is a reasonable cause that prevented the assessee from filing the appeal within the statutory time limit. Accordingly, we condone the delay in filing the appeal and proceed to adjudicate the matter on merits. On the merits of the case: 6. We observe that the learned CIT(A) dismissed the appeal ex-parte as there was no representation from the assessee. While it is true....