AI Drafter 
TaxTMI 
TaxTMI 
2026 (2) TMI 1425
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....o not require repetition, were discussed. In those averments, it is submission of assessee that he is a differently-abled person and that he had to manage medical exigences of himself and his family members which has led to the delay. Ld. AR emphasized that the delay has occurred due to onerous circumstances and it is not attributable to assessee's lethargy, negligence or malafide intention. He prayed to condone delay. The Ld. DR for revenue does not have any objection if the bench condones delay and accordingly left it to the wisdom of bench. We have considered the explanation advanced by assessee and in absence of any contrary fact or material on record, the assessee is found to have a "sufficient cause" for delay in filing present appeal. We find that section 253(5) of the Act empowers the ITAT to admit an appeal after expiry of prescribed time, if there is a "sufficient cause" for not presenting appeal within prescribed time. It is also a settled position by Hon'ble Supreme Court in Collector, Land Acquisition Vs Mst. Katiji and others 1987 AIR 1353, 1987 2 SCC 387 that whenever substantial justice and technical considerations are opposed to each other, the cause of sub....
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....n of the assessee is considered but the same is not acceptable. The provisions of section 10(10AA) of the are very clear that the exemption on account of leave encashment is exempt in respect of Central Government or State Govt employees and for other the exemption limit is Rs 3,00,000/-. Assessee ceased to exist as Central Govt employee on the day of absorption in BSNL. As per Rule 37A/37B clause (4), "on permanent absorption of the Govt services, such employees shall cease to be Govt servants and they shall be deemed to have retired from Govt service." Finally, the AO allowed exemption of Rs. 3,00,000/- only as per section 10(10AA)(ii) as against the exemption of Rs. 12,85,132/- claimed by assessee on account of leave encashment. In effect, the AO made an addition of Rs. 9,85,132/-. (iv) Aggrieved, the assessee carried matter in first-appeal but did not get any success. (v) Now, the assessee has come in next appeal before us. 5. Originally, the assessee raised following grounds in Appeal Memo (Form No. 36): "1. The Ld. AO was not justified in passing the order, which is bad in law, void ab initio, barred by limitation, illegal, contrary to t....
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....the Ld. AR submitted that the ceiling limit of Rs. 3,00,000/- (as considered by AO in assessment-order) for giving exemption, was revised to Rs. 25,00,000/- by CBDT through Notification No. 31/2023/F. No. 200/3/2023-ITA-I dated 24.05.2023. He submitted that revised limit will apply to the previous year 2019-20 / AY 2020-21 with which we are concerned. For this proposition, Ld. AR relied upon following decisions: S. No. Citation A.Y., P.B. Gist of the Case 1 Govardhan Deepchand Bhambhani v. ITO, Ahmedabad (DB) [2025] 177 taxmann.com 220 (Ahmedabad - Trib.) [28-07-2025] ITA No. 289/AHD/2025 2020-21, PB 60-64 The Hon'ble Tribunal held that after CBDT Notification No. 31/2023 enhancing the leave-encashment exemption limit to Rs. 25,00,000, any claim within this limit must be fully allowed u/s 10(10AA). 2 Ram Charan Gupta vs. ITO, Jaipur ITA No. 408/JPR/2022 2020-21 PB 65-71 The Hon'ble Tribunal held that after CBDT Notification No. 31/2023 enhancing the leave-encashment exemption limit to Rs. 25,00,000, any claim within this limit must be fully allowed u/s 10(10AA). The assessee's claim of Rs. 6,97,100/....
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....med in the return of income filed as exempt u/s 10(10AA) of the Act. The CPC and ld. CIT(A) contended that in the light of this specific notification being not issued the leave encashment allowable up to Rs. 3,00,000/- only whereas we note from the submission of the assessee that the assessee has relied upon the notification No. 31/2023/F.No. 200/3/2023-ITA-1 dated 24th May, 2023 and submitted that the revised limit of Rs. 25,00,000/- increased on account of leave salary is applicable and to be considered in the light of fact that government has issued this notification belatedly. The assessee has already claimed the leave salary as exemption the benefit should be given to the assessee. The similar issue has been decided by the bench in the case of Ram Charan Gupta in ITA No. 408/JP/2022 wherein the bench has already held as under :- "8. We have heard the rival contentions and perused the material placed on record. The bench noted that the assessee relying the decision of Hon'ble Delhi High Court has issued a notice to the Union of India in the case of Kamal Kumar Kalia & Ors. Vs. Union of India & Ors in WP(C) 11846/2019 dated 08.11.2019 wherein the court has given fol....
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....o. 5: "22. As noted above, the issue related to denial of exemption under Section 10(10AA) amounting to Rs. 13,12,806/-. The assessee is a salaried individual who had returned leave encashment salary received on retirement amounting to Rs. 13,12,806/- and claimed exemption of the same u/s 10(10AA) of the Act. The same was however restricted to Rs.3 lacs while processing the return of income of the assessee by the CPC in terms of the provisions of Section 10(10AA) of the Act. 23. I have noted above the contention of the Ld. Counsel for the assessee before me of various Co-ordinate Bench decisions of the ITAT, in as much as 22 cases, holding that the limit of exemption of leave encashment as per Section 10(10AA) of the Act applicable for the impugned year would be Rs.25 lacs. The Ld. Counsel for the assessee submitted the list of the said decisions vide submission dated 25-11-2025 as under :- Sr No Name of the Appellant and ITA No Name of the Employer Assessment Year ITAT Bench Date of Order 1) Mr. Ram Charan Gupta ITA No 408/JPR/2022 Bank Employee 2020-21 Jaipur 27/06/2023 2) Mr. Sa....
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....5897/DEL/2025 Canara Bank 2020-21 Delhi 29/10/2025 21) Mr. Vijay Pal Gupta ITA No 5915/DEL/2025 Canara Bank 2021-22 Delhi 29/10/2025 22) Mr. Sudhakar G. Paldewar ITA No 1781/PUN/2025 State Bank of India 2020-21 Pune 31/10/2025 24. Ld. DR fairly agreed that the issue was covered in favour of the assessee as pointed out by the Ld. Counsel before me. He was unable to bring to my notice any contrary decision of the ITAT in this regard, nor was he able to bring to my notice any decision of a higher judicial authority holding to the contrary. In view of the above I hold that the disallowance of exemption claimed by the assessee of leave encashment received under Section 10(10AA) of the Act amounting to Rs. 13,12,806/- be deleted. The appeal of the assessee is accordingly allowed." 13. Thus, in these decisions, the benches of Tribunal have applied the revised limit of Rs. 25,00,000/- to earlier AYs 2018-19, 2019-20, 2020-21 & 2021-22 after due analysis. There is no contrary decision referred by Ld. DR. In that view of matter, we accept the claim of assessee that he is entit....
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.... In Jute Corpn. of India Ltd. vs. Commissioner of Income-tax 187 ITR 688 (SC), Hon'ble Supreme Court held that the Act does not contain any express provision debarring an assessee from raising an additional ground in appeal and there is no provision in the Act placing restriction on the power of the appellate authority in entertaining an additional ground in appeal. In National Thermal Power Co. Ltd. v. CIT 229 ITR 383 (SC) [PB 130 - 133], the Hon'ble Supreme Court affirmed that the ITAT, being the final fact- finding and appellate authority, has the jurisdiction to admit and decide additional grounds at any stage of the appeal if doing so is necessary for a proper and just determination of the assessee's tax liability. The Court held that the Tribunal is not restricted only to the issues raised earlier and may consider any ground that is relevant to arrive at the correct assessment, even if such ground was not taken before the lower authorities. b. Income can be assessed below returned income In Pruthvi Brokers & Shareholders Pvt. Ltd. v. CIT 349 ITR 336 (Bom.) [PB 134 - 142], the Hon'ble Bombay High Court reaffirmed that appellat....
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....lack of 4G services, and the cost of maintaining legacy networks. ii. Salaries were delayed, operational restructuring became inevitable, and a large section of the workforce-including the assessee-comprised elderly employees who were not equipped to adapt to the new technologies being rapidly adopted by BSNL. In these circumstances, BSNL launched the so-called "Voluntary Retirement Scheme" primarily to shed surplus employees and reduce its financial burden. iii. The "VRS-2019" of BSNL was VRS only in name. In reality, it was introduced as part of an organisation-wide compulsory downsizing programme. This fact is accepted in Cabinet Decisions in 2019 and 2023. (copy enclosed) iv. The salaries of employees who did not opt for the VRS-2019 were withheld for several months. v. The Department is now proposing to introduce VRS 2.0 with an objective to lay off nearly 18,000 to 19,000 employees, clearly indicating that VRS-2019 was also driven by the same downsizing motive rather than being a genuinely voluntary scheme. vi. As the separation was, in substance, retrenchment, the Ex-gratia received by the assessee is required to be treated as Ret....
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...." and could not be construed as a voluntary exit by the employees. Consequently, the amount paid thereunder was held to be in the nature of severance/retrenchment compensation. Applying the provisions of Section 10(10B) of the Income-tax Act, the Hon'ble Bench ruled that the ex-gratia payment, being compensation paid pursuant to a policy decision of the Government to close down the undertaking, was fully exempt from tax. The Hon'ble Court thus excluded the said payment from the ambit of Section 17(3), holding that it could not be treated as "profits in lieu of salary." In effect, the payouts received by the employees were granted the benefit of retirement/ex-gratia exemption, akin to the treatment accorded to BSNL VRS beneficiaries. It is therefore prayed that the grounds of the assessee may kindly be allowed and the exemption may kindly be granted. Submitted. Ashish Goyal Advocate 17. Ld. AR invited our specific attention to Harish Kumar Vs. ITO, ITA No. 42/CHD/2025, ITAT, Chandigarh, cited by him at S. No. 2 in above Table. We re-produce below the relevant portion of order of ITAT: '3. The brief facts of the case that the Assessee was ....
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....he Assessee received first installment of compensation/ exgratia on VRS during the financial year 2019-20 upon which the claim exemption u/s 10(10B) of the Act to the Assessee has been allowed by the Ld. CIT(A) in the appellate order in relation to the assessment year 2020-21. The relevant part of the order of Ld. CIT(A) is reproduced as under :- "The appellant was employee of Department of Telecom Services. The Government of India in its Cabinet meeting dated 23.10.2019 approved the proposals of DOT for revival of BSNL and MTNL vide its Cabinet Note dated 22.10.2019. In its Circular Dated 04.11.2019 the BSNL envisaged a Scheme for effective implementation of VRS and invited options from employees under the scheme for seeking voluntary retirement. Reliance is also placed by the appellant upon the decision of Hon'ble Madras High Court in the case of M/S Hindustan Photo Film Workers Welfare Centre WP No. 18566 of 2015 dated 17.03.2017. Facts of this case is identical to the case of HTML-TD. Both the entitles were closed in similar situation. Therefore, the provisions of section 10(10B) of the Act are clearly attracted in the case of the appellant. 3.10 Further, ....
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....he case of "Sh. Sarabjit Singh vs Income Tax Officer" ITGA No. 764/Chd/2018, vide order dated 06.04.2019 has held as under :- "We have considered the rival submissions and have also gone through the record. The issue is squarely covered by the decision of the Co-ordinate Chandigarh Bench of the Tribunal the Case of other employees in similar facts and circumstances vide order dated 11.3.2019 passed in ITA No.870/Chd/2018 & Others titled as 'Sh. Rajeshwar Sharma & Others Vs. ITO'. This Tribunal observed as under: "Though in strict terms, it may not be said that the amount received by the assessee was on account of commutation of pension, however, the fact on the file is that the aforesaid amount was given by the new employer who has taken over the company from the earlier employer and he had terminated the services of the employees on account of job retrenchment. The amount was paid as a Compensation for retrenchment of services taking into consideration the length of service, basic salary, the age and other factors. In our view, the said amount is a compensation paid by the employer while terminating the services of the employee on account of 1oss of job a....
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....ssioner of Income-tax (Appeals) takes too narrow a view of the powers of the Appellate Tribunal [vide, e.g., C.I.T, v. Anand Prasad (Delhi), C.I.T. v. Karamchand Premchand P. Ltd. and C.I.T. v. Cellulose Products of India Ltd. Undoubtedly, the Tribunal will have the discretion to allow or not allow a new ground to be raised. But where the Tribunal is only required to consider a question of law arising from the facts which are on record in the assessment proceedings, we fail to see why such a question should not be allowed to be raised when it is necessary to consider that question in order to correctly assess the tax liability of an assessee." [emphasis supplied] Thus, the Hon'ble Supreme Court has clearly observed that for allowing a new claim, the facts must be on record in the assessment proceedings. The position of present case is very much clear that the assessee himself treated the scheme of BSNL as "VRS" and claimed exemption u/s 10(10C) in the original return as well as revised return. Further, there was is consideration/analysis of BSNL scheme at assessment stage by AO. Therefore, the relevant facts i.e. whether it was a kind of voluntary retiremen....
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....e view expressed by the Kerala High Court, with which we have no reason to disagree, particularly since it relies upon a decision of the Madras High Court in CED v. P. Brahadeeswaran [1987 16360 which in turn relies upon three decisions of the Supreme Court in CIT v. McMilan & Co. [1958] 33 ITR 182 ; Hukumchand Mills Ltd. v. CIT [196/] 63 JTR 232 and CIT v. Mahalakshmi Textile Mills Ltd. [19671.66 |TR 710, we answer the question of law in the affirmative, in favour of the assessee and against the revenue, and remand the matter to the file of the Assessing Officer to determine the claim of the assessee on merits." 2. In CED vs Brahadeeswaran (1987) 163 ITR 680 (Mad.)(Enclosed at Pg. 27-33), while discussing the above cases, it was held as under: 5. The decision of the Supreme Court in McMillan & Co.'s case (supra) was that the appellate authority's powers are co-equal to those of the assessing authority. The Court laid down further, that even though a particular statutory provision mentions by name, only the assessing authority and not the appellate authorities, as the repository of a given power connected with the assessment, yet, as a matter of constructi....
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....T vs Max Life Insurance Co. Ltd. (2025) 170 taxmann.com 466 (Del.)(Enclosed at Pg. 34-41), the assessee, a life insurance company, had earned interest income on account of its investments in redeemable non- convertible bonds/ debentures issued by certain public sector companies. However, due to an oversight, assessee did not make a claim of exemption in relation to interest income before AO and CIT(A). it had claimed same before ITAT. Whether since relevant facts of investment in PSU bonds/ debentures etc were available in audited balance sheet and was before AO, AO was to examine facts of investments in PSU bonds/ debenture with regard to eligibility of assessee's claim considering eligibility criteria laid down in section 10(15)(iv)(h). Whether, thus issue was to be remanded back to AO for examining claim of assessee and if claim made was as per law, same should be allowed, held yes. 4. It is a settled proposition that no tax can be collected except by the authority of law. (Article 265). Further, CBDT Circular No. 14 (XL - 35) dated 11-04-1955, insists on the respondent department not to take advantage of the ignorance of the assessee: - "Officers ....
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....he Government of India in the cabinet meeting held on 30.11.2016 decided to close down the Kota unit of IL and transfer the Palakkad unit to the Government of Kerala .... ". Based on the above facts, in para 12 it was held that the amount received was covered u/s. 10(10B). Similarly, in assessee's case the Union Cabinet had issued notification dated 29.10.2019 for revival of BSNL by cutting their losses by introducing scheme to reduce workforce. The copy of the notification were already been enclosed at page no. 10-14. 7. In the interest of justice, it is prayed that the additional ground be admitted. Submitted. Ashish Goyal Advocate 20. The Ld. AR reiterated above Supplementary Submission orally. Further, as stated by him in Para 5 of Supplementary Submission, the assessee also attached following Representation dated 21.07.2025 given by "All India Bharat Sanchar Nigam Limited Retired Executives' Association" to the Chairman, CBDT: On a query by bench as to the outcome of above Representation, Ld. AR admitted that it is yet pending. 21. Finally, Ld. AR submitted that the assessee is a differently-abled person and d....
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....onal Thermal Power Corporation (supra). The Ld. DR is having a serious objection against admissibility of the additional grounds/new claim itself. Basically, the Ld. DR's contention is that the facts relevant to this claim are not on record and hence the assessee's new claim cannot be accepted. In contending so, Ld. DR is relying upon Para 7 of National Thermal Power Corporation (supra). However, we find that in preceding Para 6 of National Thermal Power Corporation (supra), the Hon'ble Supreme Court observed thus: "6. In the case of Jute Corporation of India Ltd. v. C.I.T. (1991) 187 ITR 688, this Court, while dealing with the powers of the Appellate Assistant Commissioner observed that an appellate authority has all the powers which the original authority may have in deciding the question before it subject to the restrictions or limitations, if any, prescribed by the statutory provisions. In the absence of any statutory provision, the appellate authority is vested with all the plenary powers which the subordinate authority may have in the matter. There is no good reason to justify curtailment of the power of the Appellate Assistant Commissioner in entertainin....
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....ons relied by Ld. AR in his Synopsis as well as Supplementary Submission. We quote the relevant paras of decisions relied: (a) DCM Benetton India Ltd. Vs. CIT (2008) 173 Taxman 283 (Delhi): "4. The assessee is aggrieved by an order dated 28-7-2006 passed by the Income-tax Appellate Tribunal, Delhi Bench 'G' in ITA No. 123/D/2004 relevant for the assessment year 2001-02. 5. The assessee had incurred an expenditure of an amount of Rs. 13,10,566 as business expenditure. This was shown by the assessee as a prior period expenditure in its balance sheet for the previous year relevant to the assessment year 2003-04. However, the expenditure pertained to the previous year relevant to the assessment year 2001-02. 6. The issue was, therefore, not raised by the assessee before the Assessing Officer when its assessment for the assessment year 2001-02 was being completed nor was it raised before the Commissioner of Income-tax (Appeals) ['CIT(A)']. 7. Before the Income-tax Appellate Tribunal ('the Tribunal'), the assessee sought to raise an additional ground in this regard but this was declined by the Tribunal on the ground tha....
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....passed by the Appellate Controller". In our view, in order to be able to object to an order, it is not necessary that the objector should already have lodged his objection in that matter at any earlier stage. An objection is an objection even if it is put forward for the first time against a particular order. The real question, however, is whether the Tribunal can have jurisdiction to entertain and decide some point of law or of fact which had not been raised by the appellant, or dealt with by any of the authorities either in the course of assessment or in the course of an appeal from the assessment. For considering this question, we think, it is permissible to regard the Act, as belonging to a group, or joint family of direct tax enactments, the other fiscal measures being the Income-tax Act, 1961 the Wealth-tax Act, 1957, the Gift-tax Act, 1958 and so on. Under all these taxing enactments which form an integrated direct tax system the Tribunal has the same role to play, namely, the role of the ultimate appellate authority of fact and the penultimate decision-making authority on law. It may also be stated as a general observation covering all these enactments, that an order of ass....
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.... provision mentions by name, only the assessing authority and not the appellate authorities, as the repository of a given power connected with the assessment, yet, as a matter of construction, that power must be held to inhere even in the appellate authorities, exercisable by the appellate authorities at the appellate stage, in the same way the assessing authority would do in the assessment in the first instance. 6. In Hukumchand Mills Ltd.'s case (supra) a new point was raised for the first time before the Tribunal not by the appellant in that case, who happened to be taxpayer, but by the respondent department. The Supreme Court held that the Tribunal possessed the requisite power to entertain that new point. Referring to the rules framed by the Tribunal for regulating their own procedure, the Supreme Court held that those rules including the one relating to additional ground and the like are merely self-regulating in character and do not in any way circumscribe, or control, the power of the Tribunal as an appellate body under the Income-tax Act. 7. In Mahalakshmi Textile Mills Ltd.'s case (supra) the Supreme Court held that there was nothing in the Incom....
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.... share in the dutiable estate at any of the earlier stages of the proceedings. As the Supreme Court observed in the Mahcdukshmi Textile Mills Ltd.'s case (supra) hearing an appellant on a new or additional point is not a mere matter of discretion with the Tribunal, but the Tribunal are duty bound to hear and determine that point. In the present case, the objection put forward by the accountable person was based on a decision of this Court, striking down section 34(1)(c). The clubbing of the lineal descendant's share in the dutible estate was done by the assessing authority under this provision in the statute. When once this Court, in exercise of its special powers under the Constitution, had struck down a part of the statute as violative of article 14, that decision has got to be given effect to by the Tribunal, the moment their attention was drawn to it, in the appeal. The Tribunal could not very well ignore the effect of this Court's decision nullifying section 34(1)(c) merely on the feeble technicality that it had not occurred to the accountable person to invoke the decision of this Court at any earlier stage of the proceedings. We are, therefore, satisfied that the ....
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...., by implication, an intention on the part of the Supreme Court to overrule the three decisions which have stood without a word of contradiction in later decisions of that Court. As we pointed out McMillan & Co.'s case (supra), Hukumchand Mills Ltd.'s case (supra) and Mahalakshmi Textile Mills Ltd.'s case (supra) have not been noticed in the latest case cited for the department we do not think that the Supreme Court could have intended to throw overboard, by implication, all these well considered judgments. 12. Although we have considered the scope of the Tribunal's appellate jurisdiction purely on the basis of the decisions of the Supreme Court, we must mention that there is yet another way of reaching the same conclusion, especially that expressed by the Supreme Court in the Mahalakshmi Textile Mills Ltd.'s case (supra). In that case, as a matter of construction of the Indian Income-tax Act, the Court held that there was nothing in the taxing statute which restricts the Tribunal to the determination of question raised before the assessing authority and all Questions, whether of law or of fact, which relate to the assessment, can be raised before the T....
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....e. Indeed the absence of an appeal provision in a taxing enactment might render the enactment not only non- liberal, but also bad in point of constitutional law. 13. Given the indispensable requisites of a taxing enactment, the real function of an appeal against an assessment must be considered to be the same as the function of the assessment itself and not in any way different from it. That function, as we have earlier pointed out, is to adjust the taxpayer's liability, as far as it is humanly possible, to the correct pie and make it accord with the relevant taxing pro visions. If an assessing authority for any reason, either owing to ignorance or overzealousness or sheer devilment, makes an over-assessment and an appeal is carried from his order, the function of the appellate authority in that appeal is to set right the assessment and adjust the taxpayer's liability in accordance with the statutory provisions. In the appeal, as in the assessment, the task is one of adjustment of the tax payer's liability. This is a phrase which English Judges are fond of employing in discussion of tax matters. The function of a tax appeal is thus precisely the same as that of....
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....r fiscal enactments do not adopt the procedure codes excepting to a limited extent in the matter of summoning witnesses and the like. But we have made the mistake of adopting in our tax legislations the phraseology of the civil law, especially while establishing the machinery for the correction of errors in tax assessments. We have called these institutions of correction 'appellate Tribunals' or by some appellation containing the cognates of appeal. Thereby, however, the intention is not to make these bodies into the very images of civil appellate Courts. Those who preside over the Tribunals, as well as the professional gentlemen who practise before them, might have been instrumental in endowing these bodies with the aura or the external trappings of appellate Courts. But that is no reason why we should regard these bodies as replicas of appellate Courts functioning in civil litigation, and hem them in on all sides by procedural shackles and technical rules of all kinds, which really hinder the administration of fiscal justice according to law. 16. These are the philosophic, or basic, considerations on which we have got to comprehend the real scope of the jurisdict....
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....by "All India Bharat Sanchar Nigam Limited Retired Executives' Association" to the Chairman, CBDT (supra). 26. The decisions relied by Ld. DR are clearly distinguishable. The first decision of CIT Vs. Tolla Ram Hassomal (2006) 153 Taxman 532 (MP) has not considered the decision of Hon'ble Supreme Court in National Thermal Power Co. Ltd. (supra). Furthermore, this decision is not against admission of additional ground/claim. In this decision, the Hon'ble High Court has approved the Tribunal's order accepting additional ground. The only thing which has happened is that the Hon'ble High Court took a view to remand matter to CIT(A). The second decision of Oriental Science Apparatus Workshop Vs. ITO (1983) 6 ITD 541 (Chd) is dated 23.03.1983 which was given before the decision of Hon'ble Supreme Court in National Thermal Power Co. Ltd. (supra) dated 04.12.1996. The third decision of Ram Kumar Jalan Vs. Commissioner of Income-tax (1977) 108 ITR 301 (Bom) is also dated 15.07.1976 rendered before the decision of Hon'ble Supreme Court in National Thermal Power Co. Ltd. (supra) dated 04.12.1996 and also the facts of case are also different. The fourth and last ....
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....nsider entire submission of assessee judiciously with open/uninfluenced mind and decide this issue afresh. Consequently, the additional grounds are allowed for statistical purpose. 28. Resultantly, this appeal is partly allowed for statistical purpose. Order pronounced in open court on 27/02/2026. ============= Document 1Before the Hon'ble Income-tax Appellate Tribunal, Indore Bench, Indore Application for Condonation of Delay Assessee :Narendra Kumar Mishra, Bhopal Appeal No. : ITA 233/IND/2025 A.Y. : 2020-21 May it please your honours, 1. The order of the learned CIT(A) is dated 12.06.2023. The limitation for filing the appeal expired on 12.08.2023. However, the present appeal has been filed on 28.02.2025, resulting in a delay of 566 days, as computed by the Registry. 2. The delay occurred due to circumstances entirely beyond the appellant's control. During this period, the appellant was continuously engaged in the treatment and care of his father, who was suffering from prostate cancer, urinary complications and related issues, requiring regular medical attention and full-time support. 3. The appellant, being physically disabled, was simultaneo....