When Professional Negligence Meets Harsh Limitation – ITAT Steps In to Protect Assessee

Harjivanbhai Makanbhai Barasara Vs ITO (ITAT Rajkot)

Assessee filed quantum & penalty appeals with heavy delay: 2 years 3 months in quantum appeal & over 1 year in penalty appeal. CIT(A)/NFAC dismissed both solely on limitation without examining merits. Assessee explained through affidavit that he is an uneducated individual who fully relied on his CA/advocate; despite receiving documents from Assessee, the CA negligently failed to file appeals in time. Assessee argued that he should not suffer for the professional�

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