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2019 (1) TMI 1327 - AT - Income TaxDelay in filing appeal before the Tribunal - Reasons for delay - Reopening of assessment - as per delay in filing of appeal before the Tribunal was not due to any carelessness and it was beyond the control of the assessee as he was under belief that the appeal before the Ld. CIT(A) is still pending - Held that:- An examination of the affidavit filed by the assessee and extracted at para 2 hereinbefore indicates that the nature and source of knowledge has not been disclosed with sufficient particularity by the deponent (the assessee). He could have mentioned the name of his friend’s son. He could have mentioned the date in the month of July and December 2017 referred by him. The deponent (assessee) has not done so. In the instant case the assessee has not disclosed with sufficient particularity the nature and source of knowledge. Thereby, the other side is precluded to verify it and make an effective answer. delay in filing appeal before the Tribunal - decided against assessee
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