ORDER

Date : 24-09-2020 Heard Mr. G. N. Sahewalla, learned senior counsel assisted by Ms. S. Todi, learned counsel for the petitioner. Also heard Mr. S. Sarma, learned senior standing counsel for the Income Tax Department (NER).

2. This writ petition has been filed by the petitioner, being aggrieved, by the rejection of the appeal filed by the petitioner as an assessee under Section 250 of the Income Tax Act, 1961. It is submitted by the learned senior counsel for the petitioner that pursuant to the proceedings under Section 147 of the Income Tax Act an assessment was made by the Assessing Officer seeking recovery of an amount of Rs.34,06,170/-.

3. Being aggrieved, the petitioner preferred an appeal under Section 250 before the Commissioner of Income Tax (Appeals), Dibrugarh. However, by order dated 26.02.2019, the appeal preferred by the petitioner/assessee was rejected on the ground of delay by holding that the grounds urged for condonation of delay that the delay had occurred due to the pendency of a petition filed by the petitioner under Section 154 and the grounds taken in the appeal have no connection.

4. The learned senior counsel for the petitioner submits that because of the e