TMI Blog2021 (1) TMI 842X X X X Extracts X X X X X X X X Extracts X X X X ..... , as of now, all teaching problems would have been solved. Therefore, bearing in mind the fact situation in the year 2016, we are of the view that the appeals need not have been rejected by the CIT-A on the ground that they were not e-filed within the period of limitation. Appeal filed by the Revenue is dismissed - Tax Case Appeal No.507 of 2020 - - - Dated:- 11-1-2021 - Honourable Mr. Justice T.S. Sivagnanam And The Honourable Ms. Justice R.N. Manjula For the Appellant : Mr.J.Narayanaswamy, SSC For the Respondent : Mr.N.Devanathan JUDGMENT T.S.SIVAGNANAM ,J This appeal has been filed by the Revenue under Section 260A of the Income Tax Act, 1961 ('the Act' for brevity) challenging the order dated 04.12. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enior Standing Counsel appearing for the appellant/Revenue and Mr.N.Devanathan, learned counsel accepting notice for the respondent/assessee. 4. The issue involved in this case is as to whether the manual appeal filed by the assessee before the Commissioner of Income Tax (Appeals)-15, Chennai [for short the CIT(A)] could have been reckoned as proper filing of appeal on the ground that the e-appeal was filed much after filing of the manual appeal. 5. An identical question came up for consideration before this Court and a Division Bench of this Court, to which, one of us (TSSJ) was a party, held in favour of the assessee and against the Revenue in the decision in the case of CIT Vs. A.A.Antony others [TCA. Nos.432, 433 and 436 o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... submitted that the assesees may be sent back to the CITA to file an application for condonation of delay and the CITA may be directed to consider the same in accordance with law. 15. We are of the view that if we are to direct the assessees to adopt such a procedure, as argued by the learned standing counsel, it would be very harsh on the assessees, especially when the appeals are of the year 2016-2017 and even assuming if it is done, the contention which were advanced before us by Mr.A.S.Sriraman, learned counsel for the assessee would be once more again advanced before the CITA and ultimately, lead to another round of litigation on the issue of limitation alone, which we feel should not happen. 16. That apart, as observed earlie ..... X X X X Extracts X X X X X X X X Extracts X X X X
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