Delay cannot be condoned for sympathy or merely out of benevolence

The Puttur Co-operative Town Bank Limited Vs Director of Income-tax (Intelligence & Criminal Investigation) (ITAT Bangalore) There is a delay of more than 700 days in filing the appeals before the CIT(A) (except for assessment year 2008-2009, wherein the delay is 651 days). The reasons stated for belated filing of the appeals before the CIT(A) is that by mistake the assessee has filed appeals as against orders passed u/s 271FA of the I.T. Act before the ITAT and the ITAT dismissed the appeal vide order dated 27.07.2018 stating that the appeal does not lie to the ITAT but to the CIT(A). How...