P C SNEHAL ENGINEERS PRIVATE LIMITED,NAVRANGPURA AHMEDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), AHMEDABAD

ITA 1173/AHD/2026Status: DisposedITAT Ahmedabad14 July 2026AY 2014-156 pages
AI SummaryRemanded

What were the facts?

The assessee filed appeals before the CIT(A) with a delay. The CIT(A) dismissed the appeals without adjudicating on merits due to the delay. The assessee explained the delay was due to a director's health issue and lack of knowledge among other directors.

What did the Tribunal hold?

The Tribunal held that the CIT(A) should have condoned the delay and adjudicated the appeals on merits, especially since they pertained to penalty orders. The matter was set aside to the CIT(A) for re-adjudication.

What were the issues?

Whether the CIT(A) erred in dismissing the appeals on grounds of limitation without condoning the delay and adjudicating on merits.

Which sections of the Income-tax Act were involved?

Section 271BA,Section 271G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, AHMEDABAD

Before: MS SUCHITRA KAMBLE & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri Manoj Acharya, AR
For Respondent: Shri Abhijit, SR-DR
Hearing: 19.05.2026Pronounced: 14.07.2026

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

These two appeals are filed by the assessee against the separate orders of National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “CIT(A)”] both dated 09.12.2025 for the Assessment Year (A.Y.) 2014-15 in the proceedings u/s 271BA and u/s. 271G of the Income Tax Act [hereinafter referred as “the Act”].

2.

There was delay of 35 days in filing of this appeal. The assessee has filed a condonation application explaining the reason for delay. It is submitted that the matter of filing the appeal was referred to Tax Advisor M/s. Jayamal Thakore & Co., (Chartered Accountant). How

The order continues below.

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