MUTHUKKARUPPAIAH PARVATHI,PUDUKKOTTAI vs. AO, PUDUKKOTTAI

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ITA 821/CHNY/2026Status: DisposedITAT Chennai30 April 2026AY 2020-20213 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found merit in the assessee's argument regarding her limited knowledge and directed the CIT(A) to reconsider the delay, condone it, and decide the appeal on merits.

What were the facts?

The assessee's appeal before the CIT(A) was delayed by 245 days. The CIT(A) dismissed the appeal for want of sufficient cause for the delay. The assessee, a rural woman with limited knowledge of tax laws, sought a remand to explain the delay.

What were the issues?

Whether the delay in filing the appeal before the CIT(A) was sufficiently explained and if the appeal should be decided on merits.

Which sections of the Income-tax Act were involved?

Section 69A,Section 147,Section 144B

AI-generated summary — verify with the full judgment below

Before: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunatha

Hearing: 15.04.2026Pronounced: 30.04.2026

आदेश/O R D E R

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order dated 05.02.2026 passed by the ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi for Assessment Year 2020-21.

2.

At the outset, it is noted that the Assessing Officer [‘AO’ in short] determined the income of the assessee at Rs.1,23,75,460/-, inter alia,

2 I.T.A. I.T.A. No.821/Chny/2026 I.T.A. I.T.A. No.821/Chny/2026 No.821/Chny/2026 No.821/Chny/2026

making additions on variation in respect of unexplained money u/s. 69A of

the Income-tax Act, 1961 [‘the Act’ in short] and variation in respect of

subsidy received from IOC vide his order dated 25.02.2025 passed u/s.

147 r.w.s. 144B of the Act. We find the assessee challenged the same

before the ld.CIT(A) with a delay of 245 days. The ld.CIT(A) discussed

the explanation offered by the assessee in Para no. 6 of the impugned

order by recording his reasons held that the assessee failed to show

sufficient cause in filing the appeal in time.

3.

The ld.AR, Mr. V. Rajkumar, CA, refers to Para no.7 of ld.CIT(A)’s

order and submits that the assessee is a rural women engaged in small,

informal money lending activity and has limited knowledge of Income-tax

law and procedures. He submits that the assessee was not aware of the

appellate remedy or the statutory time limit. She approached the tax

professional only at a later stage and prayed to remand the matter to the

file of the ld.CIT(A) to consider the explanation and condone the delay

and adjudicate the issues on merits.

4.

The ld.DR, Ms. Gouthami Manivasagam, Addl.CIT, reported no

objection.

3 I.T.A. I.T.A. No.821/Chny/2026 I.T.A. I.T.A. No.821/Chny/2026 No.821/Chny/2026 No.821/Chny/2026

5.

We find that the ld.CIT(A) reproduced the reasons explained by the

assessee in Para no.7 of the impugned order. By reading of the same we

find force in the arguments of the ld.AR, thereby we direct the ld.CIT(A) to

consider the said reasons afresh and condone the delay and decide the

issue on merits in accordance with law. The assessee is liberty to file

evidences, if any, in support of her claim. Thus, grounds raised by the

assessee are allowed for statistical purposes.

6.

In the result, appeal filed by the assessee is allowed for statistical

purposes. Order pronounced on 30th April, 2026 at Chennai.

Sd/- Sd/- (S.R. RAGHUNATHA) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER Chennai, Dated 30.04.2026 JPV/- आदेशकी'ितिलिपअ.ेिषत/Copy to: 1. अपीलाथ&/Appellant, 2.'(थ&/ Respondent, 3. आयकरआयु//CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय'ितिनिध/DR & 5. गाड$ फाईल/GF.

PRASANNA Digitally signed by PRASANNA VANI JETTY VANI JETTY Date: 2026.05.04 10:45:57 +05'30'

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