What did the Tribunal hold?

The Tribunal condoned the delay of 294 days, considering the reasons provided by the assessee as sufficient cause. The matter was remanded back to the CIT(A) to decide the appeal afresh on its merits.

The assessee filed an appeal before the CIT(A) with a delay of 294 days. The assessee cited reasons such as residing in a remote area with poor connectivity and personal illness for the delay. The CIT(A) dismissed the appeal due to this delay.

What were the issues?

Whether the delay in filing the appeal before the CIT(A) was sufficiently explained and should be condoned. The primary issue was the CIT(A)'s refusal to condone the delay.

Tagi Sonam, East Kameng vs ITO | ITAT Guwahati 2026

Income Tax Appellate Tribunal, GUWAHATI “DB” BENCH

Before: SHRI YOGESH KUMAR U.S. & SHRI RAKESH MISHRA

For Appellant: Shri Anil Kumar Agarwala, FCA

For Respondent: Shri PS Thuingaleng, CIT, DR

Hearing: 30.07.2026Pronounced: 30.07.2026

IN THE INCOME TAX APPELLATE TRIBUNAL GUWAHATI “DB” BENCH (VIRTUAL HEARING AT KOLKATA) BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI RAKESH MISHRA, ACCOUNTANT MEMBER ITA No.313/GTY/2026 Assessment Year: 2020-21

Tagi Sonam Vs. ITO, Ward-North Type III Colony, Sepa Bameng, Lakhimpur Arunachal Pradesh-790102 [PAN: CHNPS1308F] APPELLANT RESPONDENT Appellant by : Shri Anil Kumar Agarwala, FCA Respondent by : Shri PS Thuingaleng, CIT, DR Date of hearing : 30.07.2026 Date of Pronouncement : 30.07.2026 O R D E R PER YOGESH KUMAR U.S., JUDICIAL MEMBER: This Appeal is filed by the Assessee against the order of the Commissioner of Income Tax (Appeal) (‘Ld. CIT(A)’ for short) dated 25.03.2026, passed u/s 250 of the Income Tax Act, 1961 (“the Act”, for short) for the Assessment Year 2020-21.

Brief facts of the case are that, an Assessment Order came to be passed u/s 147 r.w.s. 144 r.w.s.144B of the Act on 05.02.2025 by making certain additions. Aggrieved by the Assessment Order dated 05.02.2025, Assessee preferred an Appeal before the Ld. CIT(A). The Ld. CIT(A) vide Order dated 25.03.2026, dismissed the Appeal of the

ITA No.313/GTY/2026 Tagi Sonam; A.Y: 2020-21 Assessee. As against the order of the Ld. CIT(A) dated 25.03.2026, Assessee filed the present Appeal.

The Learned Counsel for the Assessee submitted that, though there was sufficient cause to condone the delay, the Ld. CIT(A) committed error in not condoning the delay and dismissing the first Appeals, thus, sought for allowing the Appeal.

The Ld. Departmental Representative vehemently submitted that there was no sufficient cause to condone the inordinate delay of 294 days in filing the Appeal before the Ld. CIT(A), therefore, the Ld. CIT(A) has rightly dismissed the first appeal of the Assessee on delay in latches. Thus, sought for dismissal of the Appeal.

We have heard the parties and perused the material available on record. Aggrieved by the Assessment Orders, Assessee preferred Appeal before the Ld. CIT(A) with a delay of 294 days. The Assessee in order to condone the delay before the Ld. CIT(A) in filing the appeal assigned following reasons.

“The assessee resides in a remote part of Arunachal Pradesh which suffers from poor connectivity and lack of basic infrastructure and due to these constraints, the assessee had no effective access to information regarding the assessment

ITA No.313/GTY/2026 Tagi Sonam; A.Y: 2020-21 proceedings and became aware of the assessment only upon receipt of a reminder letter from the jurisdictional Income Tax Office. Further the assessee was also not keeping well for a considerable period which further contributed to the delay in taking appropriate steps. The delay in filing the present appeal is thus neither intentional nor deliberate but occurred due to circumstances beyond the control of the assessee and the assessee therefore humbly prays that the inadvertent delay may kindly be condoned in the interest of justice.”

However, the Ld. CIT(A) has not condoned the delay and dismissed the above Appeals.

It is expected from the Assessee to file the Appeal on time, if the cause for delay is bona- fide and beyond the control of the Assessee, the same can be construed as sufficient cause. The Hon'ble Supreme Court time and again clarified that the delay in filing the Appeal with sufficient cause should be looked into in a liberal way and shall condone the delay. In the landmark decision in Collector, Land & Acquisition vs. Mst. Katiji& Others (1987) 167 ITR 471 (SC), the Hon'ble Supreme Court settled the law that the delay when supported by justifiable reasons, must make way for the cause of substantial justice. Considering the above facts and circumstances, we condone

ITA No.313/GTY/2026 Tagi Sonam; A.Y: 2020-21 the delay of 294 days in filing the first Appeal before the Ld. CIT(A) and remand the matter to the file of the Ld. CIT(A) with a direction to the Ld. CIT(A) to decide the Appeal afresh on its merits in accordance with law after providing opportunity of being heard to the Assessee.

In the result, Appeal of the Assessee is partly allowed for statistical purposes.

Order pronounced on 30.07.2026. Sd/- Sd/- (RAKESH MISHRA) (YOGESH KUMAR U.S.) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 30.07.2026 DP, PS Copy of the order forwarded to: 1. Appellant 2. Respondent 3. Pr. CIT 4. CIT(A) 5. CIT(DR) //TRUE COPY//

ASSISTANT REGISTRAR KOLKATA BENCHES, KOLKATA

TAGI SONAM,EAST KAMENG vs. INCOME TAX OFFICER WARD- NORTH LAKHIMPUR, WARD- NORTH LAKHIMPUR

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