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TMI Blog2024 (8) TMI 547X X X X Extracts X X X X X X X X Extracts X X X X ..... d delay of 1638 days. The assessee, submitted its response against the said outstanding demand on the income tax portal on 11.06.2019 continued pursuing the same till it received the rejection of his prayer for rectification on 01.08.2023. It appears that the assessee was under a bonafide belief that his grievances raised through the income tax portal shall be resolved in due course of time. This expectation of assessee caused such a huge delay in filing first appeal. It is well established principle of law that the substantial justice cannot be denied on technical aberrations. The object of prescribing procedure is to advance the cause of justice. In an adversial justice system like ours, no party should ordinarily be denied the opportunit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the very outset, learned representative for the appellant assessee has, apart from the submissions related to the merits, submitted that the assessee received intimation order dated 13.05.2019 passed u/s. 143(1) of the Act on 13.05.2019 for the A.Y. 2018 19. The assessee raised his grievance against the said order on the Income Tax portal on 11.06.2019, in respect of assessee s claim of deduction u/s. 80P(2)(d) of the Act. Thereafter on 06.07.2019, 11.02.2020, 28.07.2021, 27.12.2022. The assessee continued raising its grievances. Assessee received response on 01.08.2023 that its grievances being beyond the scope of rectification u/s. 154 of the Act was rejected. The appeal before learned CIT(A) could not be filed within the statutory perio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f time. This expectation of assessee caused such a huge delay in filing first appeal. 8. It is well established principle of law that the substantial justice cannot be denied on technical aberrations. The object of prescribing procedure is to advance the cause of justice. In an adversial justice system like ours, no party should ordinarily be denied the opportunity of participating in the process of justice dispensation. Justice is the goal of jurisprudence. Any interpretation which eludes or frustrates the recipient of justice, is not to be followed. The provisions relating to the condonation of delay, need to be interpreted liberally. 9. The object of prescribing the time period for filing of the appeal, is to expedite the proceedings bef ..... X X X X Extracts X X X X X X X X Extracts X X X X
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