Appellate Tribunal dismissed the appeal of the assessee against the order under section 263 of the  Act  there was no reasonable cause and the assessee has taken conscious decision not to file appeal against the revision order on the basis of legal opinion . Accordingly the delay of 458 days in filing the appeal was not condoned . On   appeal the High Court held that in the interest of justice the delay in filing of an appeal  was condoned and the appellant was directed to pay costs of Rs 25000 to the Maharashtra State legal Services Authority  . ( ITA No. 1210 of 2017 dt – 4 -2 -2020 ) ( AY. 2008 -09)