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TMI Blog2024 (9) TMI 1127X X X X Extracts X X X X X X X X Extracts X X X X ..... any wrong in rejecting the Miscellaneous Application on the basis that it has no power to condone the delay. There is no provision in Section 254 or any other section which provides for condonation of delay beyond six months. In the circumstances, for reasons recorded by us no sufficient cause is shown for the delay. We have observed Petitioner was not only negligent but also lacked bonafides. Writ Petition dismissed. No order as to costs. - K. R. SHRIRAM AND DR. NEELA GOKHALE JJ. For the Petitioner: Mr. N.M.Porwal For the Respondents: Mr. Suresh Kumar PC:- 1. The Writ Petition is filed to impugn an order dated 12th July 2021 passed by the Income Tax Appellate Tribunal ( ITAT ) in Miscellaneous Application No. 41/MUM/2021. The reason why ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e same would not be applicable to the present case. 4. Mr. Porwal submitted that in Khushalchand B. Daga (supra), the Court has referred to a judgment of the Allahabad High Court in a case of Income Tax Officer, Lucknow v. S. B. Singersingh and Sons , (1970) 75 ITR 646. where the Court held, even its express power to review its orders is not conferred by a statute, a Court or a Tribunal has inherent jurisdiction to rectify a wrong committed by itself when that wrong causes prejudice to a party for what that party is not responsible . Again this would not be applicable into the facts of this case because the ITAT has not committed any wrong in rejecting the Miscellaneous Application on the basis that it has no power to condone the delay. 5. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rder of stay in any proceedings relating to an appeal filed under sub- section (1) of section 253, for a period not exceeding one hundred and eighty days from the date of such order subject to the condition that the assessee deposits not less than twenty percent of the amount of tax, interest, fee, penalty, or any other sum payable under the provisions of this Act, or furnishes security of equal amount in respect thereof and the Appellate Tribunal shall dispose of the appeal with in the said period of stay specified in that order; Provided further that no extension of stay shall be granted by the Appellate Tribunal, where such appeal is not so disposed of with in the said period of stay as specified in the order of stay, unless the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X
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