2025 (6) TMI 76

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.... and circumstances of the Appellant's case, the learned Commissioner of Income Tax (Appeals) has grossly erred in points of law and facts. 2. In law and in facts and circumstances of the Appellant's case, the learned Commissioner of Income Tax (Appeals) has erred in holding that appeal was filed late and therefore, he did not condone alleged delay. It is submitted that appeal was filed in time. Appeal was filed on 29/05/2024 against rejection of our grievance on 23/04/2024 and received by us on 30/04/2024. 3. In law and in facts and circumstances of the Appellant's case, the learned Commissioner of Income Tax (Appeals) has grossly erred in not granting credit of TDS amounting to Rs 35,493. 4. In law an....

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....ircumstances of the Appellant's case, the learned Commissioner of Income Tax (Appeals) has grossly erred in points of law and facts. 2. In law and in facts and circumstances of the Appellant's case, the learned Commissioner of Income Tax (Appeals) has erred in holding that appeal was filed late and therefore, he did not condone alleged delay. It is submitted that appeal was filed in time. Appeal was filed on 29/05/2024 against rejection of our grievance on 23/04/2024 and received by us on 30/04/2024. 3. In law and in facts and circumstances of the Appellant's case, the learned Commissioner of Income Tax (Appeals) has grossly erred in not granting credit of TDS amounting to Rs 41,697. 4. In law and in f....

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....fore the Tribunal which is delayed by 104 days thereby stating that the trustee forgot to submit the order of the CIT(A) to the chartered accountant of the trust. Since the delay before the Tribunal has been explained by the assessee trust and it appears genuine, hence the delay is condoned. 6. The ld. A.R. submitted that the rectification application was made within the stipulated time i.e. on 13-04-2023 as during the covet period, the Hon'ble Apex Court has directed to exclude the period of limitation due to Covid till 28th Feb, 2022. The ld. A.R. submitted that the order for CPGRAM Grievance Application was closed on 23-04-2024 in respect of rectification application, therefore assessee trust has rightly filed the appeal within the st....