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2025 (6) TMI 73

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....eena Lal, Senior AR ORDER PER PRAKASH CHAND YADAV, JM : The present appeal of the assessee is arising from the order of the National Faceless Appeal Centre / learned Commissioner of Income-tax (Appeals ["CIT(A)" for short] dated 06.10.2023, having DIN & Order No.ITBA/NFAC/S/250/ 2023-24/1056855205(1) and relates to the assessment year 2018-2019. 2. At the outset, it is observed that there is a....

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....T. The reasons given by the assessee would itself prove that the assessee has received the order of CIT(A) on 6th October, 2023, therefore, it is not a case where the order of the CIT(A) has not been served upon the assessee. In our view, merely because merger proceedings were going on between the assessee and the Kerala Bank, that cannot be a ground for not following the Income Tax matters with d....

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.... the case. "If negligence can be attributed to the appellant, then necessarily the delay which has not been condoned by the Tribunal and affirmed by the High Court deserves to be accepted. However, if no fault can be laid at the doors of the appellant and cause shown is sufficient then we are of the considered view that both the Tribunal and the High Court were in error in not adopting a liberal ....