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Accordingly, in terms of our aforesaid observations the order of the CIT(A) is set aside and, the disallowance of Rs. 24,62,357 made by the AO is vacated.

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Section 253(5) of the Income Tax Act, 1961 — Appeal — Appeallate Tribunal — Delay of 17 days in filing appeal being on account of bonafide ommision on part of assessee's tax consultant could not be said to be attributable to assessee hence condoned — Knight Frank India P. Ltd. vs. Assistant Commissioner of income tax [2020] 203 TTJ (Mumbai) 117

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