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Facts
The assessee filed multiple appeals against orders passed by NFAC for reassessment under Section 147 r.w.s. 144 for various assessment years. The appeals were filed with a significant delay and without any petition for condonation.
Held
The Tribunal noted that the appeals were time-barred by 440 days and no reasons for the delay were provided. Despite notices being sent through RPAD and email, the assessee did not respond. Consequently, the appeals were dismissed.
Key Issues
Whether the appeals are liable to be dismissed in limine due to being time-barred and lack of response from the assessee despite sufficient notice.
Sections Cited
147, 144
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Income Tax Appellate Tribunal, ‘B’ BENCH
Before: SHRI AMIT SHUKLA & MS. PADMAVATHY S
आदेश / O R D E R PER AMIT SHUKLA (J.M): The aforesaid appeals have been filed by the assessee against separate impugned orders of even date 29/02/2024 Bharat Nathalal Zaveri passed by NFAC, Delhi for the quantum of assessment passed under Section.147 r.w.s. 144 for the A.Yrs. 2012-13, 2013-14, 2015-16 and 2016-17.
At the outset, it is noticed that appeal of the assessee is time barred by 440 days. Alongwith appeal there is no petition for condonation of delay or any affidavit giving any reasons for such a huge delay. Further, it is noticed that this appeal was fixed twice earlier and notices were sent through RPAD to the registered address given in Form 36 and also to the e-mail address provided by the assessee. Despite service of such notice through RPAD and e-mail, there has been no response by the assessee. Accordingly, appeals of the assessee are dismissed being barred by 440 days.
In the result, all the appeals of the assessee are dismissed in limine. Order pronounced on 27th October, 2025.