Delay impliedly condoned if CIT(A) inspite of declining condonation has considered and decided matter on merits

Nafees Sultana Vs ITO (ITAT Hyderabad)

ITAT Hyderabad held that CIT(A) inspite of declining to condone the delay considered and decided the matter on merits means that CIT(A) has impliedly condoned the delay involved in the appeal.

Facts- Based on information, AO initiated proceedings u/s 147 of the Act. Notice u/s 148 of the Act, dated 29-03-2021 was issued to the assessee. As the assessee during the course of the assessment proceedings failed to file the requisite details, therefore, the A.O. vide his order passed u/s 147 r.w.s. 144 r.w.s. 144B of the “A

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