TMI Blog2015 (9) TMI 919X X X X Extracts X X X X X X X X Extracts X X X X ..... ating the fact that there could be some bona fide belief on the part of the assessee that inasmuch as EODCs stand issued and stand filed with the Revenue and that being the only dispute, no further action is required to be taken by them, we are of the view that the late filing of the appeal is not with any mala fide or does not reflect any intentional lapse on the part of the assessee. We accordin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... DGFT for showing the utilization of the materials imported under the DEEC Scheme and used for the export purposes. The show-cause notice was issued in the year 2006 and they had applied for issuance of the EODCs and as they had applied for issuance of the EODCs, they requested the Revenue authorities to keep the proceedings in abeyance. The same was not adjudicated till 2013 and thereafter the OIO ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... issioner(Appeals) which was accordingly done. 4. By appreciating above conduct of the appellant and by appreciating the fact that there could be some bona fide belief on the part of the assessee that inasmuch as EODCs stand issued and stand filed with the Revenue and that being the only dispute, no further action is required to be taken by them, we are of the view that the late filing of the ap ..... X X X X Extracts X X X X X X X X Extracts X X X X
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