The appeal of the assessee was delayed by 3389 days . The affidavit filed by the assesee  was rejected by observing that “. Thus examining the present case on the touchstone of above, we find that in this case there has been inordinate delay of about 10 years in filing the appeal. Firstly, the assessee had submitted that it was an inadvertent error. In another affidavit assessee had tried to submit that appeal papers were prepared but were not filed without any reason by the Chartered Accountant. The submission is not supported for its veracity or reasoning. Furthermore, there is no rationale in allowing a person to file an appeal after ten years simply because ten years ago also he had thought of filing the appeal. There can be many reasons why a person having thought of filing an appeal may decide not to pursue the matter. Hence, the contents of the second submission cannot be treated but as an afterthought.”  On appeal High Court also affirmed the order of the Tribunal . ( referred  Collector, Land Acquisition v. Mst. Katiji (1987  ) 167 ITR 471 (SC)  Cenzer Industries Ltd.,  v. ITO  dt 15th January, 2016 passed in NM Nos.492 of 2015 and 493 of 2015 in ITA (L) Nos.2079 and 2077 of 2014 (Bom) (HC) .( ITA No.3403/Mum/2014 dt 28 -02 -2017   (AY.2001-02.)   (ITA No 1269 of 2017  dt 28 -01 -2020  )