TMI Blog2019 (12) TMI 1485X X X X Extracts X X X X X X X X Extracts X X X X ..... , electronically on 25.02.2019, the Revenue had not sent any other communication in respect of any of the demand raised in the impugned orders and reason canvassed by the assessee towards the delay in filing these appeals have sufficient and reasonable cause and hence, it was prayed to condone the delay in filing each of these appeals, we find that the reason canvassed by the assessee towards the delay in filing the impugned appeals appears reasonable and sufficient and hence, we condone the delay in filing each of these appeals and remit these appeals back to the ld.CIT(A) for deciding each of them on merits after affording effective opportunity to the assessee. It is clear from the above that the CPC was processing the orders from Janu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... we condone the delay in filing each of these appeals and remit these appeals back to the ld.CIT(A) for deciding each of them on merits after affording effective opportunity to the assessee. - ITA Nos. 2540 to 2576/Chny/2019 - - - Dated:- 5-12-2019 - Shri N.R.S. Ganesan, Judicial Member And Shri S. Jayaraman, Accountant Member For the Appellant: Shri N. Arjun Raj, CA for Shri S. Sridhar, Advocate. For the Respondent : Shri AR.V. Sreenivasan, JCIT. ORDER Per Bench: The assessee filed the above 37 appeals against the consolidated order passed by the Commissioner of Income Tax (Appeals)-17, Chennai in ITA Nos.523 to 557/18-19 09 10/19-20 dated 25.07.2019 for the assessment years 2009-10 to 2019-20. 2. M/s. B ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l the appeals, holding that the assessee did not bring any material in support of its reasons. Aggrieved against the orders of the ld.CIT(A), the assessee filed these 37 appeals. 3. The ld.AR submitted that the ld.CIT(A) dismissed the impugned appeals without giving proper opportunity to the assessee and without assigning proper reasons and justification, on technical ground, which is wholly unjustified and untenable. Inviting our attention to the reason cited by the assessee, the ld.AR submitted that the assessee, interalia, explained that how it was unaware of the change from the conventional system of service to e-system of service of the impugned orders and when the recovery notice dated 25.02.2019 was electronically received, it cam ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... transmitting a copy thereof to the deductor,- (a) by electronic mail; or (b) by placing such copy in the registered electronic account of the deductor on the portal of the Cell; or (c) by any mode mentioned in sub-section (1) of section 282 of the Act. (2) The date of posting of any communication under sub-paragraph (1) in the electronic mail or electronic account of the deductor in the portal of the Cell shall be deemed to be the date of service of such communication. (3) The intimation, orders and notices shall be computer generated and need not carry physical signature of the person issuing it. Relying on the above, the ld. DR submitted that the date on which a copy of the impugned order (s) was/ were ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and sufficient and hence, we condone the delay in filing each of these appeals and remit these appeals back to the ld.CIT(A) for deciding each of them on merits after affording effective opportunity to the assessee. 6. Further, it is clear from the above that the CPC was processing the orders from January, 2011 onwards. However, the CBDT issued the above notification on 15.01. 2013 only which indicates that there were gaps between the manual system and the electronic system which required proper administration and hence, the CBDT addressed such problems through the impugned notification. Though, the Revenue claimed to have served the impugned orders electronically, the assessee pleads that they were not brought to its notice and the Rev ..... X X X X Extracts X X X X X X X X Extracts X X X X
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