Half-Way Condonation Invalid: Time-Barred Appeal Can’t See Merits

Sanjay Kumar Vs ITO (ITAT Delhi) No Split Personality Orders- Condonation Can’t Be Half-Way: Delay Dismissed, Merits Decided? Not Permissible, Says ITAT partly allowed the assessee’s appeal and restored the matter to the file of the CIT(A) after finding serious infirmity in the appellate approach. CIT(A) had dismissed the first appeal on the ground of delay of more than one year and yet proceeded to adjudicate the appeal on merits, ultimately rejecting it again. The Tribunal held that once an appeal is dismissed as time-barred, the CIT(A) has no jurisdiction to decide it on merits, and suc...