Condonation of 2564-Day Delay Allowed as No Undue Benefit from Not Appealing Assessment Order

Model Exim Vs PCIT (Central) (ITAT Lucknow)

Conclusion: Assessee’s failure to file an appeal or pursue an alternative remedy under Section 263 of the Income Tax Act, 1961, could not be considered as negligence, as there was no undue benefit to be gained by not appealing against an assessment or related order. Assessee explained the 2564 days delay in filing of the appeal and such delay was bona fide and reasonable, then, the Courts must take a liberal approach and condone the delay in filing of the appeal.

Held: In the instant case, there

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