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2024 (1) TMI 862

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..... sessee came to know about the intimation when the action of demand for recovery came to the knowledge of the assessee - A.R. submitted that the delay is due to the reasonable cause of bonafide belief about mistake which is rectifiable u/s. 154 and without any malafide intention to defraud Revenue - HELD THAT:- It is pertinent to note that though the delay is that of 2929 days but whether the intim .....

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..... efore the CIT(A). Needless to say, the assessee be given opportunity of hearing by following principles of natural justice. Appeal of the assessee is partly allowed for statistical purposes. - Ms. Suchitra Kamble, Judicial Member For the Assessee : Shri H.V. Doshi, A.R. For the Revenue : Ms. Saumya Pandey Jain, Sr. D.R. ORDER This is an appeal filed against the order dated 1 .....

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..... income as declared in the ITR by the assessee as contract income under other revenue as per the intimation order u/s. 143(1) dated 02-07-2015. 4. Being aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee. 5. The ld. A.R. submitted that the CIT(A) has dismissed the appeal on the basis of delay in filing the appeal of .....

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..... e which is rectifiable u/s. 154 and without any malafide intention to defraud Revenue. 6. The ld. D.R. relied upon the order of CIT(A) and submitted that the assessee has not taken cognizant measures to follow of the intimation issued by CPC as well as valid verifiable order u/s. 154. 7. Heard both the parties and perused all the relevant materials available on record. It is pertinent to not .....

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