2025 (6) TMI 889

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....EMBER : The captioned appeal at the instance of assessee pertaining to A.Y. 2018-19 is directed against the order dated 24.04.2024 passed by Addl./JCIT(A), Vadodara u/s. 250 of the Income-tax Act, 1961 (in short 'the Act') arising out of the Intimation order dated 06.03.2020 passed u/s. 143(1)(a) of the Act. 2. This is the second round before this Tribunal inasmuch as the earlier exparte order o....

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....nce the issue is small therefore even though the order of ld.CIT(A) is not on merits, same can be adjudicated by this Hon'ble Tribunal and in support he referred to certain decisions placed in the paper book. 5. On the other hand, ld. Departmental Representative stated that the matter needs to be restored to the file of ld.CIT(A) if the delay in filing the appeal is condoned. 6. We have heard th....

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....aper book. This process took lot of time and in the meantime time limit for filing appeal before ld.CIT(A) has expired. Though the assessee preferred appeal before ld.CIT(A) the same was dismissed in limine being barred by limitation by three years. We considering the facts and circumstances of the case find that the delay was not intentional and the assessee would not have benefitted by filing th....

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....eal by the appellant was unintentional, much less due to any deliberate laches, and was well-explained by the State before the High Court. Hon'ble Court further held that in cases where the merits are significant, a more liberal approach may be adopted to allow for the examination of the case on its merits. Considering the ratio laid down by the Hon'ble Court in the case of Inder Singh (supra), we....