Allowing the appeal the Court held, that the reason for delay in filing the appeal to the Tribunal was prima facie shown to be bona fide. The record showed that the time spent diligently pursuing the review or rectification application ought to have been condoned and the facts had to be seen in a cluster not in fragmented. Consequently, the delay of 530 days in filing the appeal before the Tribunal had to be condoned. Matter remanded to the Tribunal to decide on merits. (AY. 2018-19)
Sidharth Co-operative Credit and Thrift Society Ltd v. ITO (2025) 478 ITR 424 (Chhattigarh)(HC)
S. 253 : Appellate Tribunal-Appeals-Delay of 530 days in filing appeal-Delay because assessee was pursuing rectification and review options-Delay must be condoned-Matter remanded to the Tribunal to decide on merits. [S. 80P(2)(a)(i), 260A]
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