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2022 (8) TMI 1302 - AT - Income TaxCondonation of delay filling appeal before ITAT - delay of 2985 days in filing the appeal by the assessee - HELD THAT:- It is appropriate to quote at this stage the legal maxim “VIGILANTIBUS, NON. DORMIENTIBUS, JURA SUBVENIUNT” which means, law will help only those who are vigilant. Law will not assist those who are careless of his/her right. Only those persons, who are watchful and careful of using his/her rights, are entitled to the benefits of law. Thus law confers rights on persons who are vigilant of their rights. The assessee could not demonstrate the reasons for non appearance before the lower authorities as well as before this Tribunal and the reasons stated in the affidavit filed by the assessee is not reasonable cause to condone the huge delay of 2985 days in filing the appeal by the assessee. Further there is no supporting affidavit of the so called accountant Mr. Parashottambhai Rajgor who alleged to have not intimated the receipt of the assessment order, as well as the appellate order to the assessee. In the absence of the same, the reasons given by the assessee is not convincing and therefore the delay of 2985 days in filing the above appeal cannot be condoned. Appeal filed by the Assessee is hereby dismissed.
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