The Commissioner (Appeals) dismissed the appeal on the ground that it was delayed by 551 days, whereas the actual delay was only four days after considering the pandemic-related extensions. The Tribunal held that the Commissioner (Appeals) proceeded on an incorrect factual premise. The matter was restored to the Commissioner (Appeals) for fresh consideration of the application for condonation of delay and, if the delay was condoned, for disposal of the appeal on merits in accordance with law. (AY. 2019-20).