Delay of 1964 days cannot be condoned for mere Ignorance of Law

Petitioner approached the Tribunal with a delay of 1964 days. The Tribunal by a detailed order refused to condone the delay. The only ground raised in the affidavit accompanying delay condonation application was the lack of understanding of the assessee with respect to the relevant procedure and the provisions of the Act. It is trite that ignorance of the law is not an excuse and lack of understanding would also be

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