Delay Condoned Due to Bona Fide Reason: Penalty Appeal Revived

Satbir Kumar Sarlia Vs ITO (ITAT Mumbai) VSV Settlement for Quantum Does Not Wipe Out Independent 271D Penalty-960-Day Delay Condoned; Penalty u/s 271D Remanded— Assessee filed appeal against penalty u/s 271D of ₹1,38,00,000 for alleged acceptance of cash loans above ₹20,000 in violation of s.269SS. Appeal was delayed by 960 days. Assessee submitted affidavit explaining that he had opted for Vivad Se Vishwas (VSV) only for quantum proceedings & believed rectification u/s 154 (pending before CIT(A)) would resolve the issue; hence appeal before Tribunal was filed belatedly as a protect...