DEVGURU EDUCATION, RAIPUR,RAIPUR vs. ITO-3(1), RAIPUR, RAIPUR

ITA 197/RPR/2026Status: DisposedITAT Raipur15 July 2026AY 2018-196 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal found merit in the assessee's submission regarding the defunct email address and the lack of awareness of the order. Citing Supreme Court judgments, the Tribunal held that substantial justice should be preferred over technical considerations.

What were the facts?

The assessee's appeal before the CIT(A) was dismissed due to a delay of 54 days in filing. The assessee claimed the delay occurred because notices were sent to a defunct email address, and they were unaware of the CIT(A)'s order.

What were the issues?

Whether the CIT(A) was justified in dismissing the appeal solely on the ground of delay without considering the reasons for the delay and the merits of the case. Whether the delay in filing the appeal should be condoned in the interest of substantial justice.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 144,Section 144B,Section 56(2)(x),Section 2(47)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH, RAIPUR

Before: JUSTICE (RETD.) SHRI C. V. BHADANG & SHRI R. K. PANDA

For Appellant: Shri Yash Jain, CA
For Respondent: Shri Piyush Tripathi, Sr. DR

PER R.K. PANDA, VP:

This appeal filed by the assessee is directed against the order dated 12.01.2026 of the Ld. Commissioner of Income Tax [CIT(A)] / NFAC, Delhi relating to assessment year 2018-19. 2. Although a number of grounds have been raised by the assessee, however, these all relate to the order of the Ld. CIT(A) / NFAC in dismissing the appeal filed by the assessee due to delay in filing of the same by 54 days.

3.

Facts of the case, in brief, are that the assessee is a firm and filed its return of income on 31.10.2018 declaring NIL income. The case of the assessee was 2 Devguru Education, Raipur

reopened under section 147 of the A

The order continues below.

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