P&H: Refuses to condone 441-day delay in Income Tax appeal, says assessee showed no sufficient cause

(i) Income Tax Act, 1961, S.249(2), 249(3) — Appeal before CIT(A) — Condonation of delay — Expression “sufficient cause” is not to be construed pedantically, but applicant must explain what prevented him from approaching appellate authority within limitation and explanation must satisfy the test of...

(ii) Income Tax Act, 1961, S.249(3) — Condonation of delay — Inordinate delay due to ill-health — Where explanation covers only part of delay and there is no material such as medical certificate, prescription or hospital record to substantiate remaining period, bare and general plea...

(iii) Income Tax Act, 1961, S.249(3) — Condonation of delay — Negligence and inaction — Appellant own conduct at assessment stage is relevant and telling circumstances, as remained inactive and did not cooperate even at assessment stage, refused statutory notices and failed to produce books...

(iv) Income Tax Act, 1961, S.260-A — Substantial question of law — Concurrent findings on delay — Where CIT(A) and Tribunal concurrently find, on proper appreciation of facts, that no sufficient cause was made out for condonation of delay, such finding is one of fact...