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TMI Blog2022 (5) TMI 732X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee s legal consultant stated that intimation is factually incorrect and application for rectification u/s.154 of the Act shall be filed - HELD THAT:- We noted from the application for condonation and affidavit filed, that the reasons stated are for the intimation order passed u/s.143(1) of the Act and not the revision order. Hence, we find no reason to condone the delay and hence, the appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e services of notice on various occasions, none is present and hence, we proceed to decide this appeal ex-parte after hearing ld. Senior DR. 3. From the facts, it is noticed that the appeal is time barred by 95 days and the assessee has filed affidavit stating the reasons. The revision order passed by PCIT is dated 28.03.2019 and it was communicated to the assessee on that very day as per recor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3) That as per the said intimation I found that my returned income has been enhanced by Rs.9,08,505/- and a consequential demand of Rs. Has been made against me. 4) That I was advised by my legal consultant that the said intimation is factually incorrect and an application for rectification under section 154 shall be filed. 5) That I was advised by the legal consultant to file an a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to ld. Senior DR, he stated that the assessee in his affidavit or application is not talking about delay occurred on the order of revision passed by the PCIT and hence, no reason is cited. 5. After hearing ld. Senior DR, we noted from the application for condonation and affidavit filed, that the reasons stated are for the intimation order passed u/s.143(1) of the Act and not the revision order ..... X X X X Extracts X X X X X X X X Extracts X X X X
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