2025 (11) TMI 232

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....he learned Advocate appearing for the appellant submits that, the appellant is an individual assessee. The appellant was dependent upon his accountant in so far as the income tax matters are concerned. He submits that, the accountant did not inform the appellant as to the notices issued during the course of the assessment proceedings relating to the said assessment year nor complied with such notices. He submits that, the accountant left the job. Consequently, the appellant was in the dark as to the entire proceedings. 3. Learned Advocate appearing for the appellant draws the attention to the Court to the explanation offered in Form 35 with regard to the condonation of delay. He acknowledges that, the explanation offered in column 15 For....

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....and filing the appeal. The decision of the appellate authority dated October 8, 2024 in this regard was upheld by the Income Tax Appellate Tribunal by the impugned order dated June 12, 2025. 8. With the deepest of respect, both the appellate authority as well as the Income Tax Appellate Tribunal proceeded to construe the explanation offered by the appellant in seeking the condonation of delay to be insufficient. It is trite law that, the appellate authority is to consider an application for condonation of delay, leniently. At the same time, the appellate authority is not required to render the condonation of delay as a mere formality. In the given case, if sufficient explanation is given with regard to the delay caused in preferring the ....