1,817-Day Delay Without Reason: ITAT Upholds Dismissal of Time-Barred Appeal

Alakapuri Sai Mandiram Trust Vs ITO (ITAT Hyderabad)

The Trust filed an appeal before the CIT(A) 1,817 days late against a 143(1) intimation. CIT(A) refused to condone the delay because the Trust did not provide any reasonable or sufficient cause for such an extraordinary lapse.

Before the ITAT, the Trust again could not demonstrate any justifiable reason for the huge delay. The Tribunal held that condonation under Section 249(3) is a discretionary power, exercisable only when a genuine cause is shown. Here, no explanation whatsoever had been provided either before CIT(A) or

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