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2023 (2) TMI 84 - AT - Income TaxCondonation of delay - huge delay of more than 2500 days in filing of the appeals before the Ld.CIT(A) - Levy of late fees u/s.234E - HELD THAT:- No doubt, as per the judgments of various Courts, while a liberal approach is to be normally taken in considering the application for condonation of delay, because substantial justice deserves to be preferred over technical consideration, but it is equally true that a person invoking the discretion of the appellate authority in inordinately belated appeals is required to show compelling cause, the operation of which was beyond its control. In this case, as per facts available on record, we find that the delay is not for a month or two, but is for a significantly large period of 2500 days. It is well settled that a distinction must be made between a case where the delay is inordinate and where the delay is of few days only. In our considered view, these appeals fall within the former category. The quantum of delay makes it manifestly evident that these appeals were not prosecuted with due care. Therefore, no error in the reasons given by the Ld.CIT(A) to dismiss appeals filed by the assessee unadmitted for delay in filing of the appeals - Appeals filed by the assessee are dismissed.
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