(1.) THIS appeal has been preferred by the assessee under s. 260A of the IT Act, 1961 (in short, 'the Act') against the order
(2.) SUBSTANTIAL question of law proposed in the appeal, which has been pressed is in para 7(1), which is as under :
(3.) AGGRIEVED by the order of assessment, the assessee had preferred an appeal before the CIT(A). The same was barred by five months. The CIT(A) dismissed the same with the following observations :