Bhujbal Construction Company Vs ITO (ITAT Pune)
ITAT Pune held that delay of 2086 days in filing of an appeal against CIT(A) not condonable as sufficient cause or sufficient reason not shown for inordinate delay.
Facts- The assesse, a partnership firm, which filed its return of income declaring total income of ₹630/- on 13/03/2014. The case of the assessee was subjected to limited scrutiny under CASS System. In the event of assessee’s failure to deduct tax at source from the expenditure of interest ₹20,35,033/-debited to Profit & Loss Account and credited eight identified persons were disallowed u/s 40(a)(ia) of the Act and the assessment vide order dt. 22/03/2016 was accordingly framed u/s 143(3) of the Act.
CIT(A) dismissed the appeal. Being aggrieved, the present appeal is filed.
Conclusion- Held that, there is neither a plausible explanation nor any whisper in the entire narration of delay or about a single step taken to showcase the required seriousness, and not even an affirmation that delay was undeliberate or unintentional. The appellant assessee before both first & second appellate proceedings dejectedly failed to demonstrate that there was ‘sufficient cause’ or ‘sufficient reason’ behind the inordinate delay caused in filing the appeal before Ld. CIT(A).
