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2026 Supreme(Online)(ITAT) 7864

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Vikram Singh Yadav, Accountant Member, Rahul Chaudhary, Judicial Member
Umesh A. Mishra – Appellant
Versus
Income Tax Officer Ward 10(3)(1), Mumbai – Respondent


Advocates:
For the Appellant/Assessee: Shri K. Gopal & Shri Om Kandalkar
For the Respondent/Department: Shri Manish Ajudiya

Table of Content
1. appeal against nfac dismissal with 1414-day delay. (Para 1 , 2)
2. condone delay for sufficient cause favoring substantial justice. (Para 3 , 4 , 5)
3. admit additional ground on jurisdictional defect in 143(2) notice. (Para 6 , 7 , 8 , 9 , 10)
4. cbdt instruction no.1/2011 mandates dc/ac jurisdiction over inr 20l income. (Para 11 , 12 , 13 , 14)
5. quash invalid 143(2) notice and assessment order. (Para 15 , 16)

ORDER

Per Rahul Chaudhary, Judicial Member:

1. The present appeal preferred by the Assessee is directed against the Order, dated 12/08/2021, passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’ whereby Learned CIT(A) had dismissed the appeal against the Assessment Order, dated 16/12/2016, passed under Section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], for the Assessment Year 2014-2015.

2. There was delay of 1414 days in filing the present appeal before the Tribunal. When the appeal was taken up for hearing Learned Authorized Representative for the Assessee appearing before us submitted that the delay in filing the present appeal be condoned and in this regard reliance was placed upon

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