2025 (11) TMI 1475

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....d to as 'the Act'). 2. It is found that there was a delay of 816 days in filing of this appeal. No condonation application was filed by the assessee along with Form no. 36. The Registry had issued two letters on 20.02.2025 and thereafter on 27.02.2025 to the assessee to file the affidavit for condoning the delay in filing the present appeal. However, no condonation application has been filed by the assessee even in the course of hearing. 3. The brief facts of the case are that the assessee had filed his return of income for the A.Y. 2014-15 on 10.10.2014 declaring total income of Rs. 2,05,200/-. The case was selected for scrutiny by issue of notice under Section 143(2) of the Act dated 18.09.2015. It was found that the assessee had sh....

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....al before us. The following grounds have been taken in this appeal: - "1. The order passed by lower authorities is bad in law and required to be quashed. 2. Ld. AO erred in law and on facts in passing assessment order despite of fact that he does not have jurisdiction to assess the assessee and accordingly, the order passed by AO is required to be quashed. 3. Ld. NFAC erred in law and on facts in treating agriculture income of Rs. 6,92,476/- as income from other sources. 4. Ld. NFAC ought to have considered submission of the appellant and ought to have deleted the disallowance. 5. Charging of Interest u/s 234A,234B,234C & 234D are unjustified. 6. Initiation of penalty proceedings u/s.271....

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....-tax return from the said quantum of land. 8. We have considered the rival submissions. At the outset, the assessee has not explained the inordinate delay of 816 days in filing the present appeal. It is found that the assessee, after receipt of the assessment order, had filed the appeal before the Ld. CIT(A) well within the time. Under such circumstances, the contention of the assessee that he was unaware about the intricacies of Income-tax proceedings cannot be accepted. In the absence of any explanation for this inordinate delay of 816 days in filing of this appeal, the same is liable to be rejected in limine. The assessee also can't escape by placing the blame for the delay on the counsel. Hon'ble Supreme Court has upheld in the case ....