ACIT, GUWAHATI vs. DAULAL SARDA AND SONS HUF, GUWAHATI

ITA 334/GTY/2025Status: DisposedITAT Guwahati03 July 2026AY 2017-189 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the assessee was aware of the proceedings for the Section 154 notice and the subsequent order dated 27.06.2022, as evidenced by a stay petition. Therefore, the CIT(A) wrongly condoned the delay without reasonable cause.

What were the facts?

The Revenue appealed the CIT(A)'s order which condoned the assessee's delay in filing an appeal against a Section 154 rectification order. The assessee initially appealed an order dated 27.06.2022 but later claimed it was an oversight and intended to appeal an order dated 18.01.2019.

What were the issues?

Whether the CIT(A) erred in condoning the delay in filing the appeal against the rectification order, and whether the assessee had knowledge of the rectification proceedings.

Which sections of the Income-tax Act were involved?

Section 154,Section 143(3),Section 153A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, GUWAHATI BENCH, GUWAHATI

For Appellant: Shri S.P. Bhati, FCA
For Respondent: Shri Santosh Kumar Karnani, Addl. CIT
Hearing: 21.05.2026Pronounced: 03.07.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

This is an appeal filed by the Revenue against the order passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Commissioner of Income Tax (Appeals), Central, NER, Guwahati [hereinafter referred to as “the Ld. CIT(A)] dated 31.07.2025, DIN & order

2 Daulal Sarda and Sons HUF No. ITBA/APL/S/250/2025-26/1079112907(1) on the following grounds of appeal:

“1. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in granting condonation of the delay in filing of appeals

The order continues below.

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