Sanjay Gopal Pandit v. NFAC (2022)95 ITR 81 (SN)(Mum) (Trib)

S. 251 : Appeal-Commissioner (Appeals)-Powers Delay in filing-Dismissal of appeal-Delay condoned-Directed to adjudicate on merits. [S.200A(1), 234E, 250]

Held that rules of procedure are handmaid of justice. Further, when substantial justice and technical considerations are pitted against each other, the cause of substantial justice deserves to be preferred. Thus, the appeals were to be restored before the Commissioner (Appeals) for adjudication on the merits after condoning the delay in filing the appeals. (AY.2014-15 to 2016-17)