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TMI Blog2024 (11) TMI 494X X X X Extracts X X X X X X X X Extracts X X X X ..... easonable cause - HELD THAT:- We note that the rectification application was processed on 3.5.2021 raising a demand during the Covid 19 pandemic period. The DGM and the Manager handling the tax matters left the organisation and management was informed that tax demand would be nullified in the rectification proceedings. However the rectification order and the demand came to notice of assessee durin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stated the facts of the case are that the assessee filed return of income on 23.11.2019 declaring total income of Rs. 23,17,75,420. Return was processed on 22.6.2020 identifying discrepancy as per Form 3CD. Rectification application was filed by the assessee on 22.6.2020 and 25.1.2021 Rectification order u/s. 154 was passed on 3.3.2021 rejecting the application of the assessee and raising a deman ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ers left the organization and the management was informed that the mistake in processing the ITR by CPC would be rectified and consequential demand would be nullified. However during the course of audit report for FY 2022-23, it was noted from the e-portal that demands are still outstanding. The dela in filing the appeal is neither deliberate nor intentional, but due to bonafide reasonable cause. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in filing the appeal. We note that the rectification application was processed on 3.5.2021 raising a demand during the Covid 19 pandemic period. The DGM and the Manager handling the tax matters left the organisation and management was informed that tax demand would be nullified in the rectification proceedings. However the rectification order and the demand came to notice of assessee during audit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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