Assessee's Lackadaisical Conduct Leads to Dismissal of Income Tax Appeal

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..... rt regarding the condonation of delay in filing an appeal before the Income Tax Appellate Tribunal (ITAT). The case involved a substantial delay of 166 days, and the assessee sought condonation of the delay, citing various reasons. The High Court examined the facts, arguments presented, and the decisions of the lower authorities to arrive at its conclusion. Arguments Presented Assessee's Arg .....

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..... ited several cases where similar delays occurred due to the transition to the faceless mode. Mr. Sinha relied on various judgments, including MUNJAL BCU CENTRE OF INNOVATION AND ENTREPRENEURSHIP, LUDHIANA THROUGH ITS AUTHORIZED SIGNATORY SH. BHARAT GOEL Versus COMMISSIONER OF INCOME TAX EXEMPTIONS, CHANDIGARH - 2024 (3) TMI 479 - PUNJAB & HARYANA HIGH COURT, Sakthi Steel Trading Rep. by its Propr .....

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..... h any explanation regarding the source of the cash deposits in his bank account. Assessment Order and Subsequent Proceedings The AO, in the absence of any return of income or explanation from the assessee, treated the cash deposits of Rs. 34,67,700/- as unexplained money u/s 69A of the Income Tax Act and framed the best judgment assessment. The CIT(A) upheld the AO's order, noting the assess .....

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..... vance substantial justice, particularly when there is no motive behind the delay. However, the action that can be condoned should fall within the realm of normal human conduct or normal conduct of a litigant. Dismissal of the Appeal The High Court observed that the assessee had habitually acted in defiance of the law, not only delaying the filing of the present appeal but also adopting a lackada .....

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..... failed to provide any plausible explanation for the delay and had adopted a lackadaisical approach throughout the proceedings before the AO and the CIT(A). The court held that the assessee's conduct did not warrant condonation of the delay, as it did not fall within the realm of normal human conduct or normal conduct of a litigant. Full Text: 2024 (4) TMI 986 - CHHATTISGARH HIGH COURT
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