2025 (3) TMI 1832

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....was emanated from the order of the Learned Income-tax Officer, Ward-34(3)(6), Mumbai (in short, the "AO") passed under section 144 read with section 147 of the Act, date of order 16/12/2019. 2. The assessee has taken the following grounds and additional grounds:- "1. The Ld. CIT(A) erred in passing the order u's 250 of the Act on the ground that the appeal is delayed without appreciating the fact that there was no delay in filing the Appeal as the appeal was filed within 30 days of service of notice of demand. 2. The Appellant reserves his right to add, amend, delete and modify the above grounds of appeal." Additional ground: "1. The order passed u/s 147 r.w.s. 144 of the Act dated 16.12.2019 without a D....

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....der was not served on the assessee and was not available in the income tax portal. Finally, the assessee was aware about the assessment order after receiving the notice of demand realization. The assessee filed a letter on 11/09/2003 for issuance of the copy of the alleged assessment order. Finally, the alleged assessment order was served on the assessee on 03/10/2023 and the appeal was filed before Ld.CIT(A) on 10/10/2023. The reasons for delay in submission of appeal was duly explained before the Ld. CIT(A), which was mentioned in para 2.7 of the order. Further, it is informed the Bench that the assessment was passed exparte under section 144 for the reasons that the assessee was busy for his elder brother's treatment. The assessee filed ....