MANMOHAN,J. - (1.)Present Income Tax Appeal has been filed challenging the Order dtd. 23/12/2021 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA 1870/Del./2020 for the Assessment Year 2018-19.
(2.)Learned counsel for the Appellant states that the ITAT erred in disallowing the loss of Rs.8,67,803.00 pertaining to the Assessment Year 2017-18.
(3.)He states that the ITAT erred in law and in facts by not giving a liberal construction to Sec. 139 of the Income Tax Act, 1961 (in short 'Act') and in not appreciating the fact that the Assessee was prevented from filing the return of income within time due to circumstances which were beyond the Assessee's control. In support of his contention, he relies upon the order dtd. 9/11/2015 passed by the Metropolitan Magistrate, Vasant Kunj, New Delhi.