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2026 Supreme(Online)(ITAT) 12449

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHIV PUNJ DELHI – Appellant
Versus
COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) - 2 DELHI DELHI – Respondent


ORDER

PER C.N. PRASAD, J.M.

This appeal is filed by the assessee against the order of Ld. CIT(IT), Delhi-2 dated 03.02.2025 for the A.Y. 2019-20.

2. The assessee has filed this appeal with the delay of 84 days with the condonation petition alongwith affidavit. Referring to the petition for condonation of delay the Ld. Counsel for the assessee submitted that the order of the ld. CIT u/s.263 of the Act was passed on 03.02.2025 and the due date for filing the appeal was 30.04.2025. However, the appeal was filed by the assessee on 23.07.2025 resulting in delay of 84 days. The Ld. Counsel for the assessee submits that the assessee was out of India during that period and therefore, the delay in filing of appeal before the Tribunal was not deliberate and beyond the control of assessee.

3. The Ld. Counsel for the assessee further stated that the assessee infact filed an affidavit deposing that he was out of India during that period and the delay occurred due to circumstances beyond his control and therefore, requested for condonation of delay in filing the appeal before the Tribunal.

4. On hearing both the parties and perusing the condonation petition alongwith affidavit furnished by the assess

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