SALIM ANSARI,PATNA vs. INCOME TAX OFFICER, PATNA

ITA 26/PAT/2026Status: DisposedITAT Patna29 June 2026AY 2018-20194 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal condoned the delay of 441 days in filing the quantum appeal before the CIT(A), citing the liberal approach to delay condonation as per Supreme Court judgments. The quantum appeal and the penalty appeal were both remanded back to the CIT(A) for fresh adjudication.

What were the facts?

The assessee filed appeals before the CIT(A) with a delay of 441 days. The CIT(A) dismissed the appeals due to this delay. The assessee cited lack of awareness, being from a rural area with no academic education, and being misguided by consultants as reasons for the delay.

What were the issues?

Whether the delay in filing the appeal before the CIT(A) was sufficiently explained and should be condoned. Whether the quantum and penalty appeals should be decided on merits after condoning the delay.

Which sections of the Income-tax Act were involved?

Section 250,Section 147,Section 144,Section 270A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA BENCH

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

For Appellant: CA Gudesh Kumar, AR
For Respondent: Shri Ravi Kant, Sr. DR
Hearing: 25.06.2026Pronounced: 29.06.2026

PER YOGESH KUMAR U.S., JUDICIAL MEMBER:

These Appeals are filed by the Assessee against the orders of the NFAC, Delhi [“the Ld. CIT(A)”, for short], dated 23.12.2025 passed u/s 250 of the Income Tax Act, 1961 (“the Act”, for short) for the Assessment Year 2018-19. 2. Brief facts of the case are that, an Assessment Order came to be passed on 30.03.2023 u/s 147 r.w.s 144 of the Act by making certain addition. Further, pursuant to the Assessment Order an Order of penalty passed u/s 270A of the Act came to be passed on 13.09.2023. Aggrieved by the Assessment Order dated 30.03.2023 and Order of penalty dated 13.09.2023, Assessee preferred Appeals before the ITA Nos.22& 26/Pat/2026 Sa

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →