O R D E R

Per Rajesh Kumar, AM:

This is an appeal preferred by the assessee against the order of the Commissioner of Income Tax Appeal, Kolkata-22, (hereinafter referred to as the “Ld. CIT(A)”] dated 26.08.2025 for the AY 2018-19.

At the outset, we note that the appeal of the assessee is barred by limitation by 14 days. At the time of hearing the counsel of the assessee explained the reasons for delay in filing the appeal. The Ld. D.R did not raise any objection in condoning the delay. After hearing the rival contentions and perusing the materials available on record, we find that the delay is for bonafide and genuine reasons and , hence, we condone the delay and adjudicate the appeal.

The only issue raised by the assessee in the various grounds of appeal is against the order of Ld. CIT (A) in confirming the demand of ₹35,57,540/- as made by the Ld. AO in respect of TDS default u/s.201(1) of the Act of ₹28,39,195/- and ₹7,18,340/- being interest u/s.201(1A) of the Act by treating the assessee in default u/s.201(1) of the Act.

The facts in brief are that the assessee is engaged in the business of real estate development and during the year was in the process of developing residentia