ITAT Mumbai Condoned 182-Day Delay as Substantial Justice Prevails Over Limitation

Santosh Kumar Ramlaxman Yadav Vs ITO (ITAT Mumbai) Substantial Justice Overrides Limitation — 182-Day Delay Condoned; Ex-parte Dismissal by CIT(A) Set Aside The Tribunal held that the assessee had established sufficient and bona fide cause for the delay of 182 days in filing the appeal, noting that he was a non-resident and was genuinely unaware of the reassessment proceedings culminating in an ex-parte order under section 144 of the Act  . It was observed that there was no mala fide intention or deliberate inaction, and the Revenue failed to place any counter-affidavit or material to rebut...