SNF INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. ACIT/DCIT, CIRCLE-3(1), VISAKHAPATNAM

ITA 240/VIZ/2026Status: DisposedITAT Visakhapatnam21 August 2026AY 2012-1314 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(A) erred in dismissing the appeal as delayed, considering the technical glitches during the transition to e-filing and the physical filing within the original limitation period. The matter was remanded for adjudication on merits.

What were the facts?

The assessee filed an appeal physically due to technical difficulties with the newly introduced e-filing system. The CIT(A) dismissed the appeal as delayed by 82 days without admitting it for adjudication.

What were the issues?

Whether the appeal was rightly dismissed as time-barred due to technical issues with e-filing, and whether the transfer pricing adjustment for royalty payment was correctly made.

Which sections of the Income-tax Act were involved?

Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM DB BENCH VISAKHAPATNAM

Before: SHRI VIJAY PAL RAO & SHRI MANJUNATHA G.

Hearing: 12.08.2026Pronounced: 21.08.2026

PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the Assessee is directed against the Order dated 12.01.2026 of the learned Addl./JCIT(A)-7, Delhi, for the assessment year 2012-2013. 2 ITA.No.240/Viz./2026

2.

The assessee has raised the following grounds of appeal:

1.

“The learned Commissioner of Income-tax (Appeals) ["CIT(A)"], on the facts and in the circumstances of the case and in law, erred in holding that the appeal filed by the Appellant was delayed by 82 days and consequently dismissing the appeal without admitting it for adjudication

2.

The learned CIT(A), on the facts and in the circumstances of the case and i

The order continues below.

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