ITAT Rejects Appeal Due to 115-Day Delay Despite Jurisdictional Challenge to u/s 148 Notice

Khimjibhai Govabhai Ravriya Vs ACIT (ITAT Mumbai) Delay of 115 Days Not Condoned: Mumbai ITAT Rejects Appeal Despite Jurisdictional Challenge to s.148 Notice Tribunal dealt with Assessee’s appeal which was delayed by 115 days. Assessee explained that since CIT(A) had set aside the ex-parte order passed u/s 144 & restored the matter to AO, he was under the bona fide belief that no further appeal was needed. Later, on consulting a new professional, he learnt about an alleged jurisdictional defect in the notice issued u/s 148. He claimed that Bombay High Court & Mumbai Tribunal had rece...