Sivarama Krishnaiah Gumpena Vs ITO (ITAT Bangalore)
ITAT Bangalore condoned delay of around 6 years in filing of an appeal since the delay was not deliberate and held that bonafide belief of an assessee is sufficient cause for not filing the appeal within prescribed time limit.
Facts- The case of the assessee was selected for scrutiny. AO completed the assessment by making additions towards Interest from Bank Deposits of Rs.18,714, unexplained cash deposits into bank for Rs.5,00,000 and difference in salary income declared and as per Form 26AS to the tune of Rs.6,54,106.
The assessee in the appeal filed before the CIT(A) did not contend the issue of addition made towards bank interest. On the addition made towards difference in salary income the assessee contended only to the tune of Rs.5,60,531 and conceded the addition of Rs.93,575. The assessee contended the rest of additions made by the AO towards cash deposits and difference in returned income before the CIT(A). The CIT(A) adjudicated only the grounds raised with regard to the cash deposit and did not give any specific findings with regard to the other issues contended by the assessee.
Being aggrieved, assessee preferred an appeal before the Tribunal, however, with a considerable delay of around 6 years.
