2026 (3) TMI 1408

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.... For the Respondent : Sh. Dr. Vivek Aggarwal (CIT) Ld. DR ORDER LALIET KUMAR, (JUDICIAL MEMBER) This appeal by the assessee is directed against the order passed by the Ld. CIT(A), Panaji u/s 250 of the Income-tax Act, 1961 dated 30.04.2025 pertaining to the assessment year 2014-15. 2. Briefly stated, the facts of the case are that the assessee is a pension fund of a cooperative inst....

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....no follow-up action was taken by the said advisor, and the assessee remained unaware of the position, which ultimately resulted in the delay in filing the appeal. 4. The Ld. CIT(A), after considering the explanation, observed that the delay of about 2000 days was inordinate and the assessee had failed to substantiate its claim with any cogent evidence. It was further held that the reasons advan....

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....fide belief that the issue would be resolved therein. It was thus pleaded that in the interest of substantial justice, the delay be condoned and the matter be restored for adjudication on merits. 7. Per contra, the Ld. Departmental Representative (DR) strongly supported the order of the Ld. CIT(A). It was submitted that the delay in the present case is highly excessive and remains unexplained b....

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....sessee does not constitute sufficient cause for condonation of such an extraordinary delay. It is a settled proposition that the remedy of appeal is independent of the remedy of rectification, and the pendency of rectification proceedings does not extend or suspend the period of limitation prescribed for filing an appeal. The assessee, being a corporate entity, was expected to act with due diligen....