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2026 Supreme(Online)(ITAT) 4286

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Sandeep Gosain, Judicial Member, Prabhash Shankar, Accountant Member
Sonmrug Co-operative Housing Society Ltd – Appellant
Versus
CIT(A) – Respondent


Advocates:
For the Appellants/Petitioners: Pawan Choudhary
For the Respondents: Harendra Verma, Sr. DR

Table of Content
1. assessee's appeal delayed; internal disputes cited. (Para 1 , 2 , 4)
2. cit(a) rejected massive delay condonation. (Para 5 , 6 , 7)
3. principles for condonation require sufficient cause and diligence. (Para 8 , 9 , 10 , 11 , 12 , 13 , 14)
4. no sufficient cause; delay unjustified. (Para 15 , 16 , 17 , 18)
5. appeal dismissed; limitation rigorously applied. (Para 19 , 20 , 21)

आदेश/ORDER

PER SANDEEP GOSAIN, JM:

Firstly, we shall take ITA No. 2794/Mum/2025, A.Y 2012-13 as lead case and facts narrated therein.

The present appeal has been filed by the assessee challenging the impugned order 29.03.2024 passed u/s 250 of the Income Tax Act, 1961 (‘the Act’), by the Office of the Commissioner of Income Tax, Appeal ADDL/ JCIT (A)- 2 for the assessment year 2012-13. The following grounds are reproduced below:

“Ground of Appeal:

We have already filed an affidavit explaining reason for late filing of an appeal request for Condonation of Delay:

1. In the facts and circumstances of the case the Learned Commissioner of Income Tax (Appeal) has completely ignored on the merit of the case, and only delt with delay in filing appeal.

2. The Appellant is a registered Co-operative Housing Socie

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