What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal before the CIT(A), citing the principle of substantial justice over technicalities. The appeal was restored to the CIT(A) for fresh adjudication.

The assessee filed an appeal before the CIT(A) with a delay of 672 days. The CIT(A) 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) should be condoned based on the reasons provided by the assessee.

Late Shri Ram Narayan Through… vs ITO | ITAT Delhi 2026

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

Before: SHRI SATBEER SINGH GODARA

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. 6320/Del/2026 Assessment Year: 2017-18 Vs. Income Tax Officer, Late Shri Ram Narayan (through Legal Heir), Ward-3(3)(5), RZ 7B Fali No. 1, Syndicate Saharanpur Enclave, Delhi-110045 New Delhi PAN: ALUPN6073B (Appellant) (Respondent) Assessee by Sh. Ajay Kumar Agarwal, CA Department by Sh. Manoj Kumar, Sr. DR

Date of hearing 03.08.2026 Date of pronouncement 03.08.2026 ORDER This assessee’s appeal for assessment year 2017-18, 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/250/2024-25/1065303387(1), dated 31.05.2024 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. 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 672 days in filing of the assessee’s lower appeal instituted on 08.01.2020 against the Assessing Officer’s assessment framed on 27.12.2019, 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 its condonation petition before the CIT(A) explaining all the reasons on account of circumstances beyond his control.

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 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

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at his own risk and responsibility, in consequential proceedings. Ordered accordingly. 5. 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: 07.08.2026 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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LATE SHRI RAM NARAYAN THROUGH LEGAL HEIR,NEW DELHI vs. ITO WARD 44(3) DELHI, NEW DELHI

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