Sri Ram Mandir Katargam v. CIT (E) (2024)112 ITR 70 (SN)(Surat)(Trib)

S. 253 : Appellate Tribunal-Appeals-Delay of 506 days-Sufficient cause-Not diligent in pursuing issue relating to application-Delay is not condoned. [S.12A, 253(5)]

Held that in the absence of reasonable and satisfactory cause or even appropriate explanation for seeking condonation of delay, it is not to be condoned lightly. Condonation of delay should not be granted only on the ground that ordinarily a litigant does not stand to benefit by lodging an appeal late. The Tribunal granted liberty to the assessee to make an application and seek appropriate relief from the Commissioner (Exemptions) in terms of Circular No. 7 of 2024, dated April 25, 2024 issued by the Central Board of Direct Taxes. The Commissioner (E) may examine the application of the assessee to see if it was covered by the circular and decide the matter in accordance with law and the circular.

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