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TMI Blog2014 (7) TMI 759X X X X Extracts X X X X X X X X Extracts X X X X ..... ourt should be liberal in construing the sufficient cause and should lean in favour of such party - the delay of 31 days in filing the appeal before the Tribunal is condoned. Disallowance/ addition made – Held that:- Assessee has not provided any convincing reason for the assessee’s failure to provide the submission along with evidences to substantiate the grounds of appeal before the CIT(A), havi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee has filed a petition of condonation of delay in the shape of an affidavit. The assessee has explained the reasons for not filing the appeal within the time period of limitation as he misunderstood the advice of the consultant with regard to the time limit for filing the appeal before the Tribunal. Thus, the delay has been occurred due to the reason which is a bona fide one and not intentional o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o each other, cause of substantial justice has to be preferred. In view of this legal and factual position, we condone the delay of 31 days in filing the appeal before the Tribunal and take up the matter for adjudication. 3. In this appeal, the assessee has agitated the action of the Ld.CIT(A) in confirming various disallowances/additions made by the AO. It is pertinent to mention that the Ld.C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s of appeal before the Ld.CIT(A), having due regard to the principle of natural justice, we are of the opinion that it will be just and proper to set aside the entire appeal back to the file of the Ld.CIT(A) for fresh adjudication after giving a reasonable opportunity of being heard to the assessee placing all the materials to substantiate his claim. Considering the fact that the assessee has not ..... X X X X Extracts X X X X X X X X Extracts X X X X
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