TAI ANGU,AALO, WEST SIANG vs. INCOME TAX OFFICER, WARD, NORTH LAKHIMPUR, NORTH LAKHIMPUR

ITA 353/GTY/2026Status: DisposedITAT Guwahati17 August 2026AY 2019-204 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal condoned the delays in filing the appeals before the CIT(A) in the interest of justice and restored the issues on merits to the file of the CIT(A) for adjudication. The Tribunal noted that since no evidence was produced by the assessee before the Assessing Officer, the CIT(A) would need to consider the applicability of Rule 46A of the Income Tax Rules, 1962. The order of the CIT(A) was set aside, and the issue was remanded for adjudication on merits. The assessee was directed to file a reply before the CIT(A), and the CIT(A) was directed to strictly comply with Rule 46A, recording reasons for admission or rejection of additional evidence and granting the Assessing Officer an opportunity of being heard. The appeals were partly allowed for statistical purposes.

What were the facts?

The assessee filed appeals before the CIT(A) for assessment years 2019-20 and 2020-21. The CIT(A) dismissed these appeals on the grounds of delay in filing and the assessee's failure to present its case. The assessee had provided reasons for the delay in its appeals to the CIT(A). The assessee did not produce any evidence before the Assessing Officer. The present appeals are filed by the assessee against the orders of the CIT(A) dated 29.04.2026.

What were the issues?

1. Whether the CIT(A) erred in dismissing the appeals on the grounds of delay and non-adjudication on merits, despite the assessee providing reasons for the delay? 2. Whether the CIT(A) should have considered the appeals on merits, especially when the assessee failed to produce evidence before the Assessing Officer? Assessee's Contentions: The assessee argued that it had provided reasons for the delays in filing the appeals before the CIT(A). The assessee also contended that the appeals should be adjudicated on merits. Revenue's Contentions: The judgment does not record any specific contentions made by the revenue.

Which sections of the Income-tax Act were involved?

Section 46A,Section 251(1)(a),Section 271

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, GAUHATI BENCH

Before: SHRI GEORGE MATHAN & SHRI LAXMI PRASAD SAHU

For Appellant: Shri Sanjay Varma, FCA
For Respondent: Shri M. C. Omi Ningshen, CIT-DR
Hearing: 17.08.2026Pronounced: 17.08.2026

Per George Mathan, JM: These are the appeals filed by the assessee against the separate orders of the CIT(A), National Faceless Appeal Centre, Delhi [hereinafter referred to as the ‘CIT(A)’] all dated 29.04.2026 for the assessment years 2019-20, 2019-20, 2019-20, 2020-21, 2020-21 & 2020-21 respectively.

ITA No.352 to 357/GTY/2026

2.

Shri Sanjay Varma, FCA, represented on behalf of the assessee and Shri M. C. Omi Ningshen, CIT-DR represented on behalf of the revenue.

3.

A perusal of the orders of the ld. CIT(A) clearly shows that ld. CIT(A) has dismissed the appeals of the assessee on the ground of delays in fili

The order continues below.

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