9911796707
TMI Blog2023 (6) TMI 222X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. The Ld. DR submitted that the Tribunal vide combined order dated 14.08.2019 in ITA No.1398/Ahd/2004 had dismissed the appeals of the Revenue as "withdrawn" due to low tax effect including assessee's cases being ITA No.332/Ahd/2005 for A.Y. 1996-97, ITA No.1112/Ahd/2005 for A.Y. 1997-98, ITA No.2484/Ahd/2005 for A.Y. 1998-99, ITA No.1376/Ahd/2008 for A.Y. 1999-2000, ITA No.1091/Ahd/2006 for A.Y. 1999-2000, ITA No.1377/Ahd/2008 for A.Y. 2000-01 and ITA No.1513/Ahd/2006 for A.Y. 2001-02. The Ld. DR submitted that on verification, it was noticed that the said appeals mentioned hereinabove para falls under the exception laid down in para 10(e) of the Circular dated 11.07.2018. Accordingly, the then Income Tax Officer of the respective Ward ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ate of pronouncement i.e. 05.10.2020. * 17.12.2021 to till date - On account of change of incumbent in the office and it was in assumption that in other assessment years also, the MA is admitted as per this office communication dated 13.02.2020 but not communicated the same from the Hon'ble ITAT office. Further, delay has also occurred due to impact of the spread of the new variant of the Covid-19 and the drastic surge in the number of Covid cases across the country in that period of time (in second wave) and as such, the mater of filing of MA in this case had got overlooked. 9. It is humbly submitted that in view of the above chain of events, the delay has occurred due to bonafide reasons in filing of Miscellaneous Application by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... prefer MA with condonation request. Even after adjudication of MA for AY 1996-97, no MAs were preferred for remaining years. MAs are preferred only after part hearing of appeals for two assessment years by the Tribunal, from the bunch of appeals were placed for hearing and not before that. The Ld. AR submitted that the MA has been preferred with prior approval of Pr. CIT-3, Ahmedabad dated 04.08.2022 and the date of hearing after filing of MA for AY 1996-97 upto the date of fling are : 27.01.2021, 15.02.2021, 04.05.2021, 15.02.2022, 29.03.2022, 09.06.2022, 13.07.2022, 19.07.2022, 05.08.2022. The Ld. AR further submitted that the MAs are preferred against the dead person despite substitution of legal heir by the family members of assessee an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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