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In view of theexamination of facts and law, Tribunal isof the considered opinion that this inordinate delay in filing of MAs is not a fitcasefor condonation, more so, because there is no specific provision in the realm of section 254(2) of the Act to provide for such condonation of delay incaseof MAs.

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Sec. 254 of Income Tax Act, 1961—Appeal— The sufficient cause needs to be established by the assessee through evidences and in this case, the assessee has failed to do so, thus, the inordinate delay in filing of MAs is not a fit case for condonation, more so, because there is no specific provision in the realm of section 254(2) to provide for such condonation of delay in case of MAs, therefore, all the condonation of delay petitions are dismissed and since at the threshold itself the condonation of delay petitions are dismissed, MAs become academic and therefore, they are also dismissed. - DARYAPPUR SHETKARI SAHAKARI GINNING & PRESSING FACTORY LTD. V/s ASSTT. CIT - [2020] 82 ITR (TRIB) 547 (ITAT-NAGPUR)

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