9911796707
TMI Blog2024 (7) TMI 337X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee filed condonation petition, submitting that the mother of the managing partner was not in proper health due to her age and the he had to assist her since she has been taking treatment for a long time. He, therefore, pleaded to condone the delay and admit the appeal for hearing. 2. I have gone through the condonation petition filed by the assessee and find that the assessee was prevented by a reasonable cause to file the appeal belatedly. Hence, I condone the delay and admit the appeal for hearing. 3. Brief facts of the case as submitted by the assessee are that the assessee is a partnership firm, being assessed to tax with the same status and same PAN for the past three decades. However, the assessee found that the allotted PA ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d issued by the department, corroborate our status as a registered partnership firm. The issuance of the PAN card was based on partnership deed documentation, further affirming our classification. Lack of AOP Existence: There is no evidence or documentation indicating the existence of an Association of Persons related to our entity. The assessment completed by the Central Processing Centre (CPC) solely relied on the technical discrepancy in the PAN number, overlooking the substantive legal status of our firm. Repeated Notifications: Despite multiple notifications to the department highlighting the error in our PAN designation and requesting correction, no action was taken by the assessing officers. Unilateral Assessment: The sudden co ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has not given any sufficient reason for the delay of five months prior to the covid pandemic and also even after covid pandemic, the assessee failed to give any sufficient cause which prevented the assessee to file the appeal in time but to file the appeal beyond the period of 8 months. The Ld.DR, therefore submitted that there is no valid reason to condone the delay of 1008 days and pleaded to uphold the order of the Ld.CIT(A) and dismiss the appeal of the assessee. 7. I have heard both the parties and perused the material placed on record. In the instant case, the assessment order was passed and served on the assessee on 03.09.2019, therefore, the assessee ought to have filed appeal within 30 days before the Ld.CIT(A) from the date of re ..... X X X X Extracts X X X X X X X X Extracts X X X X
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