The assessee is required to establish that in spite of acting with due care and caution, the delay had occurred due to circumstances beyond his control and was inevitable. Accordingly the delay of 326 in filing the appeal was not condoned . Referred Oriental Aroma Chemical Industries Ltd. v. Gujarat Industrial Development Corporation (2010) 5 SCC 459 and R. B. Ramlingam v. R. B. Bhavaneshwari (2009) 1 RCR (Civil) 892 . ( AY.2006 -07)
Gurpal Singh Brar v. ITO (2018) 404 ITR 58 (P&H) (HC)
S. 260A : Appeal – High Court -Limitation-Delay of 326 days -No reasonable cause -Delay was not condoned .[ Limitation Act, 1963,S.5 ]