DEPUTY COMMISSIONER OF INCMOE RAX, MANGALURU vs. K SEETHARAM RAI, PUTTUR

ITA 2547/BANG/2025Status: DisposedITAT Bangalore31 August 2026AY 2012-1333 pages
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What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeals, citing the assessee's age, health, and circumstances as sufficient cause. It also held that unabated assessments could not be disturbed under Section 153C without specific incriminating material for those years.

What were the facts?

The assessee filed appeals with a significant delay due to age, health issues, and reliance on a consultant. The Revenue opposed the condonation of delay, citing its inordinate nature. The Tribunal considered the principles of substantial justice over technicalities.

What were the issues?

Whether the delay in filing the appeal should be condoned, and whether additions made under Section 153C were valid without specific incriminating material for unabated assessment years.

Which sections of the Income-tax Act were involved?

Section 153C,Section 132,Section 250,Section 234A,Section 234B,Section 234C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

PER SHRI WASEEM AHMED, ACCOUNTANT MEMBER:

These appeals comprised ITA Nos. 820 & 821/Bang/

The order continues below.

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