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TMI Blog2024 (8) TMI 1243X X X X Extracts X X X X X X X X Extracts X X X X ..... ough the ratio laid down in its order reported [ 2021 (11) TMI 387 - SC ORDER] we condone the delay of 614 days and with regard to 90 days delay, we observe that there is reasonable ground to condone the delay in the form of affidavit filed. Further, we find that as the ld. CIT (A) has not decided the issues on merit for AY 2018-19 and the issues involved are same in both the assessment years i.e. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Appeal Centre (NFAC) dated 18.01.2024 for the Assessment Years 2018-19 2019-20. 2. Both the appeals are interconnected having common issues. Both the appeals are heard together and disposed off by this common order. 3. At the time of hearing, ld. AR for the assessee brought to our notice that for AY 2018-19, ld. CIT (A) had not condoned the delay in filing the appeal and submitted that there were ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... both the assessment years i.e. 2018-19 2019-20, prayed that both the appeals may be remitted back to the AO with the prayer to decide the appeals after considering the documentary evidences and also giving an opportunity of being heard to the assessee. 3. On the other hand, ld. DR for the Revenue objected to the submissions of the ld. counsel for the assessee. 4. Considered the rival submissions ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sidering the documentary evidences as the ld. CIT (A) did not decide the appeal on merits. The disallowance made by the Assessing Officer needs verification of the documentary evidence filed by the assessee. Therefore, in the interest of justice, we direct Assessing Officer to consider the documentary evidences and also give an opportunity of being heard to the assessee and then decide the matter ..... X X X X Extracts X X X X X X X X Extracts X X X X
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