Dear Sir
\nCIT(A) passed order of penalty in November, 2016 but the order was not received by me as I am NRI staying outside India. I filed appeal in Hon’ble ITAT in Feb 21 with a request for condonation of delay and my appeal was admitted and the delay was condoned by Honble Tribunal in mid march 2021 stating that I can apply under VSV. Application under VSV was submitted by me before 31 March 2021. The application has been rejected by CIT citing the reason that as per FAQ 59 of FAQ circular dated 4\/12\/20 the application of delay of condonation should have been filed before 4\/12\/20, the date of issuance of FAQ circular. I have observed on net that Hoble HC in some recent judgement has ruled that FAQ 59 is erroneous and can not be part of VSV. My query is should I appeal to HC against the rejection? Is rejection under FAQ 59 of FAQ circular bad in law? sir,I need your urgent help and will be grateful if I get immediate response. <\/p>\n","protected":false},"excerpt":{"rendered":"
Dear Sir CIT(A) passed order of penalty in November, 2016 but the order was not received by me as I am NRI staying outside India. I filed appeal in Hon’ble ITAT in Feb 21 with a request for condonation of delay and my appeal was admitted and the delay was condoned by Honble Tribunal in mid march 2021 stating that I can apply under VSV. Application under VSV was submitted by me before 31 March 2021. The application has been rejected by CIT citing the reason that as per FAQ 59 of FAQ circular dated 4\/12\/20 the application of delay of condonation should have been filed before 4\/12\/20, the date of issuance of FAQ circular. I have observed on net that Hoble HC in some recent judgement has ruled that FAQ 59 is erroneous and can not be part of VSV. My query is should I appeal to HC against the rejection? Is rejection under FAQ 59 of FAQ circular bad in law? sir,I need your urgent help and will be grateful if I get immediate response.<\/p>\n