PRAMOTH CHANDRASEKARAN,ERNAKULAM vs. ITO, WARD 3(1), GURGAON

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ITA 6409/DEL/2026Status: DisposedITAT Delhi10 August 2026AY 2019-20203 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

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

What were the facts?

The assessee's appeal for AY 2019-20 was filed with a delay of 98 days. The CIT(A) had refused to condone a delay of 04 days in filing the lower appeal before it, citing lack of justifiable reasons.

What were the issues?

Whether the CIT(A) erred in refusing to condone the delay in filing the assessee's appeal without considering the reasons provided.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B

AI-generated summary — verify with the full judgment below

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

Before: SHRI SATBEER SINGH GODARA

For Appellant: Adv. (VC)
Hearing: 03.08.2026Pronounced: 03.08.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No. 6409/Del/2026 Assessment Year: 2019-20 Pramoth Chandrasekaran Vs. Income Tax Officer, New Ambatt House, Ward 3(1), Kidangoor, P.O. Vengoor, I P Estate, New Delhi- 02 Angamaly, Ernakulam- 683572 PAN: AJFPC6522R (Appellant) (Respondent) Assessee by Sh. J Saravanan, Adv. (VC) Department by Sh. Manoj Kumar, Sr. DR

Date of hearing 03.08.2026 Date of pronouncement 03.08.2026 ORDER PER SATBEER SINGH GODARA, JM: This assessee’s appeal for assessment year 2019-20, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (for short, “CIT(A)/NFAC”), Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1083612564(1), dated 12.12.2025 involving proceedings under section 147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Case called twice. None appears at the assessee’s behest. It is accordingly proceeded ex-parte.

2.

For the reasons stated in the assessee’s condonation averments, delay of 98 days in filing of the instant appeal is condoned in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).

3.

It emerges during the course of hearing with the able assistance coming from both the parties that the learned CIT(A) has refused to condone the delay of 04 days in filing of the assessee’s lower appeal instituted on 19.04.2024 against the Assessing Officer’s assessment framed on 16.03.2024, thereby holding that the same had not been explained in light of the justifiable reasons.

3.

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

4.

That being the case, we 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

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make way for the cause of substantial justice. Accordingly, the delay caused in filing the appeal before the CIT(A) is condoned and the assessee’s instant appeal is restored back to the CIT(A) 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.

6.

This assessee’s appeal is allowed for statistical purposes.

Order pronounced in the open court on 03.08.2026 Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 10.08.2026 Pooja Mittal, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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