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2020 (10) TMI 36 - HC - Income TaxCondonation of delay - delay had occurred due to the pendency of a petition filed by the petitioner under Section 154 - eligible submission of sufficient cause for delay - HELD THAT:- It is not clear from the impugned order of the CIT (Appeals) as to why a finding was recorded by the CIT (Appeals) that the rectification application u/s 154 before AO are issues which have no connection with the interest charged by the AO. CIT(Appeals) while passing the impugned order appears to have touched upon the issues which have some bearing in the outcome of the appeal preferred by the petitioner, without reference to the materials relied upon to arrive at such a finding. As in the interest of justice to remand the matter back in the Commissioner of Income Tax Act(Appeals) to re-decide afresh the issue of condonation of delay by providing adequate opportunities to the Assessee to refer to and/or rely on, any such grounds as may be sought to be relied upon her and after proper hearing in the matter.
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