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2014 (7) TMI 757 - AT - Income TaxCondonation of delay – Delay of 599 days – Change of jurisdiction - Held that:- The Department did not file the appeals within due time in the case and cause shown by it does not conclusively show that same is reasonable or sufficient - it has been already decided in assessee's own case for the earlier assessment year that State cannot be put on the same footing as an individual because individual would be quick in taking the decision whereas Government machinery, there is impersonal mechanism through its officers or servants but position here is not the same as it was not a case of similar nature and no such plea has been raised nor any reason or material in this direction has been pleaded or filed and Department has just sought condonation of delay, cannot be held to be a sufficient or reasonable cause for not filing the appeal within stipulated time – thus, the application for condonation of delay having been rejected – Decided against Revenue.
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