CHANDRASHEKHAR JANGDE,BURHANPUR vs. ITO, BURHANPUR, BURHANPUR

ITA 20/IND/2026Status: DisposedITAT Indore08 May 2026AY 2020-2113 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the belated filing of Form 10E should not result in the denial of substantial relief if the assessee is otherwise entitled to it. The time limit for filing Form 10E should be construed liberally in the given circumstances.

What were the facts?

The assessee sought relief under Section 89 of the Income Tax Act for salary paid in arrears. The assessee filed Form 10E belatedly, citing technical issues and COVID-19. The Assessing Officer (AO) and CIT(A) denied the relief due to the delay in filing Form 10E.

What were the issues?

Whether relief under Section 89 can be denied solely on the ground of belatedly filing Form 10E, and if the time limit for filing Form 10E should be interpreted liberally.

Which sections of the Income-tax Act were involved?

Section 89,Section 154,Section 143(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, INDORE BENCH, INDORE

For Appellant: Shri Soumya Bumb, CA
For Respondent: Shri Ashish Porwal, Sr.DR
Hearing: 04.05.2026Pronounced: 08.05.2026

Per Paresh M Joshi, J.M.:

This is an Appeal filed by the Assessee under section 253 of the income tax Act 1961,[ herein after referred to as the Act

for the sake of brevity] before this tribunal as & by way of a second Appeal. The Assessee is aggrieved by the order

bearingNumber:-ITBA/APL/S/250/2025-26/1082391381(1)

dated 07.11.2025 passed by the Ld. CIT(A) u/s 250 of the Act, which is herein after referred to as the “Impugned

order”. The Relevant Assessment year is 2020-21 and the Chandrashekhar Jangde ITA No. 20/Ind/2026 - A.Y.2020-21

corresponding previous year period is from 01.04.2019 to 31.03.2020. 2. Factual Matrix

2.

1 That as and by an intimation order passed u/s 143(1) of the act dated 2

The order continues below.

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