2025 (3) TMI 1976

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....hri M. Subramanian For the Revenue : Shri Alok Kumar, CIT-DR ORDER PER B.R. BASKARAN, A.M : The assessee has filed this appeal challenging the revision order dated 14-03-2022 passed by the Ld. Commissioner of Income Tax (Exemptions)-Mumbai ['Ld.CIT(E)'] u/s. 263 of the Income Tax Act, 1961 ('the Act'). 2. At the outset, we notice that the present appeal is barred by limitation by 89....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... 3. I say that my C.A. also endorsed the view that I need file appeal only against the order giving effect to the C.I.T.'s order and not against C.I.T.'s 263 order. 4. I state that the delay was not intentional or deliberate and therefore it is my earnest request that the same may please be condoned. Whatever stated by me above, is true and correct to the best of my knowledg....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....hat the assessee had filed appeal against the assessment order. 4. We notice that the AO had passed the order on 24-12-2022 and the assessee has filed the present appeal challenging the revision order after expiry of almost two years. The assessee should have taken advice of the tax counsel in December, 2022 and it is not discernible as to why the assessee should wait for almost two years to fi....