#Section 69 unexplained investments

ITAT Mumbai rules that the Commissioner of Income-tax (Appeals) must independently adjudicate both the condonation of delay in filing appeals and the validity of reassessment proceedings under Section 148A of the Income Tax Act. The order sets aside the CIT(A)'s failure to apply this dual-test standard, restoring the appeal for fresh consideration and reinforcing procedural safeguards in tax disputes.

ITAT sets aside CIT(A) order for dismissing appeal on delay grounds, remands case for fresh consideration with opportunity to file condonation application.