Appellant-society, a State instrumentality of Government of Himachal Pradesh, had filed application under section 10(23C)(vi). After rejection of said application, assessee sent documents to its counsel for filing appeal before Tribunal .However, assessee received show cause notice issued by Registry informing that assessee’s appeal was time barred.  Assessee came to know that counsel to whom documents were mailed had taken no steps to file appeal in time while assessee was under a bona fide impression that appeal had been filed in time. Tribunal dismissed  the  appeal.  Allowing the appeal of the assessee the Court held that though there was some negligence on part of assessee in not pursuing matter in respect of filing of appeal after instrument/documents were sent to its counsel, but negligence was not of such a degree that Tribunal could dismiss appeal being time barred by limitation.