PREMATIX SOFTWARE SOLUTION PRIVATE LIMITED,HOSUR vs. INCOME TAX OFFICER, CORPORATE WARD 5(2), CHENNAI, CHENNAI

D ITA 431 of 26 IRR.doc आयकर अपीलीय अिधकरण, ’डी’ �ायपीठ, चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI �ी इंटूरी रामाराव, लेखा सद� एवं �ी एस.एस. िव�ने� रिव, �ाियक सद� के सम� । Before Shri Inturi Rama Rao, Accountant Member & Shri S.S. Viswanethra Ravi, Judicial Member आयकर अपील सं./I.T.A. No.472/Chny/2026 िनधा�रण वष�/Assessment Year: 2014-15 Prematix Software Solution Vs. The Income tax Officer, Pvt., Corporate Ward 5(2), C Muruganandam, 2/122-3, Chennai-600034. 3rd Street, Nethaji Nagar, Mookandapalli, Hosur Tamil Nadu-635126.

[PAN: AAICP0469K] (अपीलाथ�/Appellant) (��थ�/Respondent) अपीलाथ� की ओर से / Appellant by : Mr. C. Sathish, C.A. ��थ� की ओर से/Respondent by : Mr. ARV Sreenivasan, CIT सुनवाई की तारीख/ Date of hearing : 17.03.2026 घोषणा की तारीख /Date of Pronouncement 12.06.2026 : 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 28.11.2025 passed by the Ld. Commissioner of Income Tax (Appeals), NFAC, Delhi for the assessment year 2014-15.

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AO under Section 147 read with Sections 144 and 144B of the Income Tax Act (for short, ‘the Act’), wherein the AO determined the income of the assessee at ₹47,32,000/- to the best of his judgment. We note that the AO issued a notice under Section 148 of the Act on 31.03.2021, but no compliance whatsoever was made by the assessee. Further, three notices under Section 142(1) of the Act were issued on three different dates, i.e., 15.11.2021, 14.12.2021 and 31.12.2021 respectively, wherein no compliance whatsoever was made by the assessee before the AO, which is evident from para No.2 of the assessment order. The ld. CIT(A) discussed the explanation offered by the assessee with reference to the delay of 139 days from para Nos.3 to 6.11 of the impugned order, wherein he discussed at length the judicial precedents with reference to negligence, callousness, inaction, want of bona fide, irresponsibility, dilatory tactics, recklessness or ruse, oversight or inexcusable indifference, or waiting for favourable judgments in para No.6.11 of the impugned order. On perusal of the entire impugned order from para Nos.3 to 6.11 thereof, we find no infirmity in the order of the ld. CIT(A) in rejecting the delay of 139 days. Before us, a statement was made by the ld. AR Mr. C. Sathish, C.A. that the orders of the AO and the ld. CIT(A) are not justified as the assessee is not in existence. On perusal of the reasons explained by the assessee with reference to the delay, which are reproduced by the ld. CIT(A) on page Nos.5 and 6 of the impugned order, it is noted that the name of the assessee was struck off by the Registrar of Companies by order dated 19.03.2022, which is after the issuance of the notice under Section 148 of the Act, which clearly shows that the assessee had ample opportunity to prosecute his case before the AO and there is no dispute with regard to the existence of the assessee for the AY under consideration relevant to the previous year 2013-14. Therefore, the

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argument of the ld. AR is rejected with reference to the contention that the order of the ld. CIT(A) is not justified as the assessee is not in existence. Thus, we find no infirmity in the order of the ld. CIT(A) in rejecting the delay condonation petition, and the same is justified. Thus, the grounds raised by the assessee are dismissed.

Sd/- Sd/- (INTURI RAMA RAO) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER Chennai, Dated, 12.06.2026 MM/- 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.