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TMI Blog2024 (8) TMI 968X X X X Extracts X X X X X X X X Extracts X X X X ..... mentioned in Form No.35 - HELD THAT:- Addl/JCIT(A) ought to have condoned the delay as the period from the date of passing the order by the AO, i.e. 09.12.2019 till 19.01.2021 is covered by the pandemic Covid-19 prevailed all over the country. Therefore, the said delay cannot be reckoned for the purpose of computation the limitation period by virtue of the judgment of the Hon ble Supreme Court in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Delhi dated 22.02.2024 for the assessment year 2006-07. 2. Briefly, the facts of the case are that a search and seizure action u/s. 132A of the Act was conducted in Tupe Group on 13.02.2009 wherein the assessee was covered. During the course of search, certain incriminating material in the form of note books, diaries and loose papers were seized which revealed land transactions of the Tupe family ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... de without any corroborative material based on loose papers. 4. Being aggrieved, the appellant preferred an appeal before the CIT(A)/NFAC with a delay of 407 days. The CIT(A)/NFAC had dismissed the appeal without condoning the delay by stating that neither the appellant had filed any condonation petition nor any reasons were mentioned in Form No.35. He, therefore, placing reliance on various decis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 12.2019 till 19.01.2021 is covered by the pandemic Covid-19 prevailed all over the country. Therefore, the said delay cannot be reckoned for the purpose of computation the limitation period by virtue of the judgment of the Hon ble Supreme Court in Cognizance for Extension of Limitation, In re 438 ITR 296 (SC) read with judgment in Cognizance for Extension of Limitation, In re 432 ITR 206 (SC) date ..... X X X X Extracts X X X X X X X X Extracts X X X X
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