Condoning delay of 5000 plus days in filing appeals - innumerable litigations - change of fortunes

Facts:

Assessee's cases were dismissed ex parte by CIT(A) on which appeal was filed by the assessee before ITAT after a delay of approx. 5000 plus days (15 years later). Stand of the assessee was that there was a change in business fortunes that had sustained unprecedented losses and there were innumerable litigations which were filed upon them by various authorities and their factory was taken over by the banker. The averments filed contained the few hundred cases filed against the assessee with a prayer for condonation for rehearing their cases once again.

Held in favour of the assessee that the unprecedented delay has been explained adequately and the cases were remanded back to the CIT(A) for proper rehearing.

Ed. Note: The decision makes a good reading of how the condonation plea has been accepted by the ITAT.

Case: Jilichem Laboratories (India) Ltd. v. ITO 2023 TaxPub(DT) 4381 (Ahd-Trib)