Dolphin Metal (India) Ltd.,, Ahmedabad vs The Income Tax Officer, Ward-1(4),, ... on 4 May, 2018
In our considered opinion "sufficient cause" as appearing in the limitation
Act should be liberally considered and the Tribunal cannot shut the door of justice
to a litigant on the score of limitation. When the reason of delay has been properly
explained, the Tribunal is to adopt a pragmatic approach to condone the delay
when there is no negligence, inaction or want of bona fide on the part of the
applicant. Therefore, keeping in view of Rule 24 of the (Income Tax Appellate
Tribunal, Rule1963), the decision of Hon'ble Jurisdictional High Court cited in the
case of Dolphin Metal (India) Ltd. vs. ITO supra, and the larger interest of the
assessee seeking to avail the ongoing Vivad se Vishwas Scheme, 2020, we find
-4-
MA No.04/Ahd/2021(In ITA No.2865/A/15)
Feelings Multimedia Ltd. vs. ITO
Asst.Year - 2011-12
that condonation of delay otherwise would not prejudice the interest of the
Revenue in any manner rather would do substantial justice to the parties.