1986 (5) TMI 50

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..... was contended by the authorised representative for the assessee that the appeal is time barred by 27 days. Office note was also to this effect. The departmental representative however submitted that the delay should be condoned in view of the application for condonation of delay dated 14/17th December, 1984 and the appeal should be heard on merits. The authorised representative for the assessee o .....

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..... ctually traced out. It is settled law that each day's delay has to be explained. But it is clear that the ITO has made an omnibus statement without giving the particulars to enable this Tribunal to ascertain whether the delay was due to some sufficient reason or not. On a careful consideration of the entire matter we are not satisfied that the appellant was presented by sufficient reasons from fil .....

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