Delay not condoned in absence of valid and genuine ground

Brijesh Charitable Trust Vs ACIT (ITAT Delhi)

Held that as the assessee has already abandoned its statutory right of filing an appeals and has consciously taken decision. Therefore, delay of more than 10 years cannot be condoned without valid and genuine ground.

Facts-

The issue related to condonation of delay of 3853 days in filing of appeal. Assessee stated that while preparing for filing of appeals against orders passed by learned Commissioner (Appeals) in the proceedings arising out of order passed by the Assessing Officer under section 154 of the Act, the counsel for the assessee had advised that it is necessary to challenge the orders passed by learned Commissioner (Appeals) in quantum proceedings. Hence, on such advice, the assessee has filed these appeals.

Conclusion-

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