Busy Officer Isn’t ‘Sufficient Cause’ – ITAT Refuses to Condone 100-Day Delay, Revenue Appeal Dismissed

ITO Vs Jayantilal Bhagwanchand (ITAT Bangalore)

Revenue filed an appeal against the order of CIT(A), but the appeal reached ITAT 100 days late. Department sought condonation of delay, claiming AO was busy with time-barring assessments, penalty work, scrutiny reports, grievance redressal & demand verification of four merged wards. They argued the delay was “unintentional” & due to heavy workload.

Assessee strongly objected, stating that such vague & routine excuses do not constitute “sufficient cause.”

Tribunal examined the legal position on condona

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