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2020 (4) TMI 849 - AT - Income TaxCondonation of delay filling Rectification application u/s 154 - disallowance u/s 14A - as held by ld. CIT(A) that the assessee has not explained the delay even after dismissal of rectification application - HELD THAT:- Before us neither the assessee has explained the delay nor filed any documentary evidence or copy of application filed before the ld. CIT(A) in seeking condonation of delay. Thus, we do not find any justifiable reason in seeking the condonation of delay before the ld. CIT(A). The ratio in the case law relied by assessee in Collector of Land Acquisition vs. Mst Katiji [1987 (2) TMI 61 - SUPREME COURT] and in Gera Developments (P.) Ltd. [2016 (8) TMI 1009 - ITAT PUNE] is not helpful to the assessee as the facts in both the case law are different. The assessee in this case was aware about the disallowance under section 14A, which was not hesitated by him by filing appeal before first appellate authority. No merit in the grounds of appeal raised by assessee.
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