1,370-Day Delay Not Condoned; Reliance on Consultant Not Sufficient Cause: ITAT Mumbai

Attivo Protezione Pvt Ltd Vs ITO (ITAT Mumbai)

The appeal filed by Attivo Protezione Pvt Ltd challenged the order dated 29.09.2021 passed under section 250 of the Income Tax Act, 1961, by the National Faceless Appeal Centre (NFAC) / CIT(A) for Assessment Year 2018-19. The primary issue concerned the condonation of a substantial delay of 1,370 days (over 3.5 years) in filing the appeal. The assessee attributed the delay solely to the alleged failure of its tax consultant to advise remedial action after the CIT(A) order.

The ITAT examined the delay under the framework of secti

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