TMI Blog2022 (11) TMI 1429X X X X Extracts X X X X X X X X Extracts X X X X ..... umstances, for AY 2011-12 and 2012-13 respectively. Neither side has brought any distinguishing facts and circumstances, or decided precedents, or any legal submissions to our consideration to persuade us to take a view different from the view taken above. Neither side has brought any materials for our consideration to persuade us to interfere with the impugned order of Ld. CIT(A). We decided the issue in dispute in the present appeal before us, in favour of the assessee - Shri Saktijit Dey, Judicial Member And Shri Anadee Nath Misshra, Accountant Member For the Appellant : Mr. Jeetender Chand, Senior Departmental Representative For the Respondent : Mr. KVSR Krishna, CA ORDER PER ANADEE NATH MISSHRA, AM: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has been filed by Revenue, on 26/03/2021 which is more than 60 days after the impugned appellate order dated 28/08/2020 of the Ld. CIT(A) was communicated (on 15/09/2020) to the learned Principal Commissioner of Income Tax. However, at the time of haring before us, representatives of both sides, the learned Counsel for the assessee as well as the learned Sr. DR for Revenue were in agreement that the appeal is to be treated as filed in time and the delay is to be condoned because the period from 15/09/2022 [the date on which impugned appellate order of the Ld. CIT(A) was communicated to the learned Principal Commissioner of Income Tax] and 26/03/2021 fell during the pandemic period of Covid-19, and was to be excluded in computation of limita ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd circumstances, or decided precedents, or any legal submissions to our consideration to persuade us to take a view different from the view taken by Co-ordinate Bench of ITAT, Delhi in aforesaid orders dated 04/10/2018 and 16/04/2021 for AY 2011-12 and AY 2012-13 respectively. Neither side has brought any materials for our consideration to persuade us to interfere with the impugned order of Ld. CIT(A). (B.2.1) In view of the foregoing; and respectfully following the aforesaid orders of the Co-ordinate Bench of ITAT, Delhi, in the specific facts and circumstances of the present appeal before us, we decided the issue in dispute in the present appeal before us, in favour of the assessee and against Revenue. Accordingly, we decline to inter ..... X X X X Extracts X X X X X X X X Extracts X X X X
|