Oversight/ workload not reasonable cause to condone delay in appeal filing

It to be settled position of law that right of appeal is neither an absolute nor an ingredient of natural justice, the principle of which must be followed in judicial and quasi-judicial adjudication. The right to appeal is a statutory right and it can be circumscribed by the condition in the grant. If a statute gives right to appeal upon certain conditions it is upon fulfilment of those conditions that the right becomes vested in and exercisable by the appellant.

As per s. 253(3), appeal is required to be filed by the assessee

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