Case Law Analysis
|Income Tax Appellate Tribunal
Section 5 Limitation Act | Bona Fide Reliance on CA’s Advice Justifies Condonation of 744-Day Delay in Tax Appeal : ITAT Delhi
ITAT Delhi condones a 744-day delay in filing a tax appeal, ruling that the assessee’s bona fide belief-based on their CA’s advice regarding abatement post-search-constitutes 'sufficient cause' under Section 5 of the Limitation Act. The decision reinforces that professional reliance, if reasonable, can override strict limitation bars in tax proceedings.