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2020 (5) TMI 594 - AT - Income TaxCondonation of delay - Rectification order u/s.154 - alternative remedy by filing application u/s. 154 - Late fee u/s. 234E - delay in filing appeal against Section 200A of the Act is 1876 days - assessee aggrieved by the order of late fee u/s. 234E but not inadvertently filed appeal before the CIT(A) against the orders passed on the intimation passed u/s. 200A of the Act but filed appeals against the orders passed u/s. 154 - HELD THAT:- Assessee has taken steps to file all these appeals with the relevant appellate authority but was pursuing only alternative remedy by filing application u/s. 154 of the Act i.e., rectification proceedings were taken up to the Tribunal and consequently, the assessee was made aware by their Chartered Accountant about the consequences of these rectification proceedings, the assessee immediately prepared the appeals and filed with the CIT(A) against intimation u/s. 200A of the Act. Admitted facts are that the assessee was pursuing alternative remedy, even though the delay is very long, we feel that the assessee has reasonable and sufficient cause for not filing these appeals against intimation u/s. 200A of the Act passed by Assessing Officer u/s. 200A of the Act before CIT(A). Since, we noticed reasonable and sufficient cause in not filing these appeals before CIT(A), we reverse the orders of CIT(A) and condone the delay. We, set aside all these appeals to the file of CIT(A).
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