Delay can't be condoned as co. intentionally didn't file appeal as it wanted to file cross objection

INCOME TAX: When it is consciously decided by assessee to not avail of right of filing appeal and instead only avail of right of filing cross objection, then fact that revenue did not file appeal, and thereby did not present assessee with an opportunity for filing cross objection, cannot constitute 'sufficient cause' for assessee for not filing appeal within time limit prescribed under section 253(3)

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