TMI Blog2017 (9) TMI 1716X X X X Extracts X X X X X X X X Extracts X X X X ..... ncy of an application before the ITAT under Section 254 (2) of the Act. In the circumstances, the question of invoking Section 14 of the LA would not arise at all. The decision relied upon by Mr. Kapoor has no application to the present case. - No satisfactory reason has been provided by the Appellant for the extraordinary delay of 439 days in the filing the appeal - Decided against the assessee. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Appellant was pursuing the alternate remedy should be excluded in terms of Section 14 of the Limitation Act 1963 (LA), Mr. Sanat Kapoor, learned counsel for the Appellant, relied on the decision of the Supreme Court in M.P. Steel Corporation v. Commissioner of Central Excise (2015) 7 SCC 758 . 3. The Court is unable to accept the submission that the application filed before the ITAT under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on before the ITAT under Section 254 (2) of the Act. In the circumstances, the question of invoking Section 14 of the LA would not arise at all. The decision relied upon by Mr. Kapoor has no application to the present case. 4. It is then submitted by Mr. Kapoor that the ITAT has been rejecting applications filed under Section 254(2) of the Act on the ground that the applicant has in the meanwhi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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