KRRISHRAJ CONSTRUCTION PVT. LTD.,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-3, SURAT

ITA 1231/SRT/2025Status: DisposedITAT Surat04 May 2026AY 2015-165 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeals, citing the reasons provided by the assessee, including the complexities arising from the Vivad Se Vishwas Scheme and the pandemic. The appellate orders were set aside, and the cases were remanded to the CIT(A) for a decision on merits.

What were the facts?

The assessee filed appeals before the ITAT after a significant delay of 1665 days. The delay was attributed to the assessee's attempt to avail the Vivad Se Vishwas Scheme, subsequent financial difficulties due to the COVID-19 pandemic, personal health issues, and communication lapses regarding the CIT(A)'s order.

What were the issues?

The primary issue was whether the delay in filing the appeals could be condoned due to the circumstances explained by the assessee. The secondary issue involved the restoration of appeals that were withdrawn due to the Vivad Se Vishwas Scheme.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 272A(1)(d),Section 253(1),Section 4,Section 5(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: DR. Arjun Lal Saini & Shri T.R. Senthil Kumar

PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-

These appeals are filed by the Assessee as against two separate appellate orders both dated 10-02-2021 passed by the Commissioner of Income Tax (Appeals)-4, Surat arising out of the reassessment order passed under section 147 r.w.s. 144 and penalty levied under section 272A(1)(d) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2015-26 and 2016-17. I.T.A Nos. 1231 & 1232 //SRT/2025 A.Ys. 2015-16 & 2016-17 2

2.

The registry has noted that there is a d

The order continues below.

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