When Professional Negligence Meets Harsh Limitation – ITAT Steps In to Protect Assessee

Harjivanbhai Makanbhai Barasara Vs ITO (ITAT Rajkot) Assessee filed quantum & penalty appeals with heavy delay: 2 years 3 months in quantum appeal & over 1 year in penalty appeal. CIT(A)/NFAC dismissed both solely on limitation without examining merits. Assessee explained through affidavit that he is an uneducated individual who fully relied on his CA/advocate; despite receiving documents from Assessee, the CA negligently failed to file appeals in time. Assessee argued that he should not suffer for the professional’s mistake. Tribunal held that the explanation was bona fide & sup...