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2020 (3) TMI 960 - AT - Income TaxCondonation of delay in filing rectification application - sufficient cause for the purpose of condonation of delay - HELD THAT:- So far as section 254(2) of the Act is concerned, there is no express power conferred on the Tribunal by the Legislature in the Statute where the Tribunal can condone the delay beyond the relevant period prescribed in the Statute therein. In the case of Collector, Land Acquisition vs. MST.Katiji & Ors. [1987 (2) TMI 61 - SUPREME COURT] relied strongly by the assessee, the Hon’ble Apex Court has referred to sufficient cause for the purpose of condonation of delay. This sufficient cause needs to be established by the assessee through evidences and in this case, the assessee has failed to do so. In view of the above examination of facts and law, we are of the considered opinion that this inordinate delay in filing of MAs is not a fit case for condonation, more so, because there is no specific provision in the realm of section 254(2) of the Act to provide for such condonation of delay in case of MAs. Therefore, all the condonation of delay petitions are dismissed. Since at the threshold itself the condonation of delay petitions are dismissed, MAs become academic and therefore, they are also dismissed - All the condonation of delay petitions and MAs are dismissed.
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