CIT(A) Cannot Dismiss in Limine: ITAT Restores Appeal for Decision u/s 250(6)

Daulat Savala Narute Vs ITO (ITAT Pune) Assessee, an individual agriculturist, faced reassessment u/s 147 r.w.s.144/144B leading to addition of ₹51,19,500 against returned income of ₹2,29,970. CIT(A) dismissed the appeal in limine, citing non-appearance & invoking the maxim Vigilantibus et non dormientibus jura subveniunt, as well as B.N. Bhattacharjee (SC) & Tukojirao Holkar (MP HC). Assessee filed appeal before ITAT with a delay of 27 days supported by affidavit explaining lack of tax knowledge, difficulty with e-assessment procedure, & failure of his consultant to follow up....