TaxTMI 
TaxTMI 
2025 (7) TMI 429
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....ere is delay of 172 days in filing the appeal before this Tribunal. Application for condonation of delay has been filed by the assessee giving rise to delay in filing the appeal and the same reads as follows : "1. The appellant submits that in the present case, the appeal order u/s 250 passed by the CIT(A), NFAC was issued on the email on 16.07.2024. Thus, the due date for filing the appeal before Hon'ble ITAT was 14.09.2024. The appeal is being filed on 05.03.2025. Thus, there is a delay of 172 days in filing the present appeal before Hon'ble ITAT. The assessee submits that the above delay in filing the appeal was on account of reasonable cause. 2. In this regard, it is submitted during the relevant time the Shri ....
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....ary, 2025 the he approached Counsel, CA Sanket Milind Joshi for filing the present appeal. Thereafter, the compilation of the relevant documents, information and generating Digital Signature Certificate took some time. Further, it is to be noted that between 19 February, 2025 to 5th March, 2024 the assessee tried to e-file the appeal via online mechanism. However, there was a technical problem viz. OTP on email was not being issued even after trying multiple times and subsequently, the appeal was filed on 05.03.2025. In view of the above facts, the appellant submits that there was a delay of 172 days in filing the present appeal. In this respect, the appellant places reliance on the ratio laid down in the decision of Honourable Supreme Cour....
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....es, 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. Having gone through the averments made in the condonation application and considering the ratio laid down by the Hon'ble Court in the case of Inder Singh (supra), I am of the view that there was 'reasonable cause' which prevented the assessee in filing the appeal within the stipulated time. I therefore condone the delay of 172 days and admit the appeal for adjudication. 4. The sole grievance of the assessee is against the finding of ld.CIT(A) confirming the adhoc addition of Rs. 22,05,077/- made by Assessing ....
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....dition u/s. 69C of the Act at Rs. 22,05,077/-. 6. Aggrieved assessee filed appeal before ld.CIT(A) but failed to succeed. Now the assessee is in appeal before this Tribunal. 7. Ld. Counsel for the assessee referring to the paper book running into 53 pages submitted that the assessee is consistently making purchases from URD and the percentage of total purchases from URD is 58.24% in A.Y. 2015-16, 46.10% in A.Y. 2016-17 and 44.28% in A.Y. 2017-18. He submitted that assessee has provided all necessary details but then ld. AO has only carried out on test-check basis and made adhoc addition whereas the URD purchases have been made from 762 persons. Ld. AO was required to make addition only to the extent of purchases which could not be ver....