What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal before the CIT(A)/NFAC, emphasizing that technicalities should not obstruct substantial justice. The appeal was restored to the CIT(A)/NFAC for fresh adjudication.

The assessee filed an appeal before the CIT(A)/NFAC with a delay of 194 days. The CIT(A)/NFAC refused to condone this delay, stating that the reasons provided were not justifiable.

What were the issues?

Whether the delay in filing the appeal before the CIT(A)/NFAC should be condoned based on the reasons provided by the assessee.

Priy Ranjan vs ITO | s.144 | ITAT Delhi 2026

Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI

Before: SHRI SATBEER SINGH GODARA

Hearing: 19.08.2026Pronounced: 19.08.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

ITA No. 7537/Del/2026, A.Y. 2023-24 Vs. Priy Ranjan Income Tax Officer, D-262, D-Block, Ward 24(1), Near Mangalam New Delhi Properties, Qutub Vihar, Phase-1, New Delhi PAN: CCSPR2600B (Appellant) (Respondent)

Assessee by Sh. Navneet Singal, CA Department by Sh. Manoj Kumar, Sr. DR

Date of hearing 19.08.2026 Date of pronouncement 19.08.2026

ORDER This assessee’s appeal for assessment year 2023-24, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1085973135(1), dated

ITA No. 7537/Del/2026

13.02.2026 involving proceedings under section 144 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.

It emerges during the course of hearing with the able assistance coming from both the parties that the learned CIT(A)/NFAC has refused to condone the delay of 194 days in filing of the assessee’s lower appeal instituted on 01.09.2025 against the Assessing Officer’s assessment framed on 19.02.2025, thereby holding that the same had not been explained in light of the justifiable reasons.

Faced with the situation, learned departmental representative could hardly dispute that the assessee had indeed filed his condonation petition before the CIT(A)/NFAC explaining all the reasons on account of circumstances beyond his control.

That being the case, I hereby quote Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC), settling the issue long back that all such technical aspects must make way for the cause of substantial justice. Accordingly, the delay caused in

ITA No. 7537/Del/2026

filing the appeal before the CIT(A)/NFAC is condoned and the assessee’s instant appeal is restored back to the CIT(A)/NFAC for its afresh appropriate adjudication within three effective opportunities subject to a rider that the taxpayer shall plead and prove the case at his own risk and responsibility, in consequential proceedings. Ordered accordingly.

This assessee’s appeal is allowed for statistical purposes.

Order pronounced in the open court on 19/08/2026

Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 31.08.2026 Binita, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

PRIY RANJAN,DELHI vs. ITO, WARD 24(1), NEW DELHI

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