What did the Tribunal hold?

The Tribunal found the assessee's reasons for the delay to be bonafide and granted an opportunity for the appeal to be adjudicated on merits. The matter was remanded to the CIT(A) with a direction to condone the delay upon payment of costs.

The assessee filed an appeal before the CIT(A) with a significant delay of 2474 days. The CIT(A) dismissed the appeal in limine due to dissatisfaction with the reasons provided for the delay.

What were the issues?

Whether the delay in filing the appeal before the CIT(A) should be condoned, and if so, whether the appeal should be adjudicated on merits.

Sheeba Gnanaseeli, Chennai vs ITO | s.143(1) | ITAT Chennai 2026

Before: SHRI S.S. VISWANETHRA RAVI & SHRI S.R. RAGHUNATHA

Hearing: 21.08.2026Pronounced: 31.08.2026

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appeal filed by the assessee is directed against the order dated 22.04.2026 passed by the ld. Commissioner of Income Tax (Appeals), Addl/JCIT(A)-2, Pune, for the assessment year 2017-18. :-2-: ITA No: 3460/Chny/2026

At the outset, it is noted that the assessee filed an appeal before

the ld.CIT(A) against the intimation dated 25.03.2019 with a delay of 2474 days. The assessee filed delay condonation petition stating the reasons which was reproduced by the ld.CIT(A) in his order at page no.6

and for non-satisfaction of reasons for delay, the ld.CIT(A) dismissed the appeal in limine.

The ld.AR, Mr. M. Sakthivel, Advocate, submits that the assessee

was under the Bonafide belief that the appeal before the ld.CIT(A) was filed and since he is not well versed in IT law, did not understand the implications of the automated adjustment made u/s. 143(1) of the Act. He argued that the issue is relating to mismatch with Form 26AS and unless this Tribunal gives a direction to ld.CIT(A) to condone the delay

and adjudicate the issue on merits, the assessee will be put to irreplaceable loss and damage.

The ld.DR, Ms. R. Anita, CIT, did not dispute the same.

Having heard both the parties, we find the reasons stated by the assessee before the ld.CIT(A) are Bonafide which really prevented the :-3-: ITA No: 3460/Chny/2026

assessee in filing the appeal in time. Considering the addition made with reference to mismatch with Form 26AS, we are of the considered opinion

that the assessee shall get another opportunity before the ld.CIT(A).

Therefore, we deem it proper to remand the matter to the file of the ld.CIT(A) with a direction that he shall condone the delay of 2474 days

on his satisfaction of payment of cost of Rs.10,000/- by the assessee in favour of the Tamil Nadu State Legal Services Authority at Hon’ble High

Court of Madras within 30 days from the date of receipt of this order.

The assessee shall furnish the proof before the ld.CIT(A). The assessee

is liberty to file evidences, if any, in support of his claim. Thus, order of the ld.CIT(A) is set aside and grounds raised by the assessee are allowed for statistical purposes.

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

purposes. Order pronounced on 31st August, 2026 at Chennai. (S.R. RAGHUNATHA) JUDICIAL MEMBER Chennai, Dated: 31.08.2026 JPV

:-4-: ITA No: 3460/Chny/2026

आदेश की (ितिलिप अ.ेिषत/Copy to: 1. अपीलाथ'/Appellant, 2.()थ'/ Respondent, 3. आयकर आयु//CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय (ितिनिध/DR & 5. गाड% फाईल/GF

PRASANNA VANI JETTY Date: 2026.09.01 15:25:11 +05'30'

SHEEBA GNANASEELI,CHENNAI vs. ITO, NCW-19(6), CHENNAI

What did the Tribunal hold?

What were the facts?

What were the issues?

Which sections of the Income-tax Act were involved?

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