SINGARAVELMUDALIAR RAVINDRAN,NAGAPATTINAM vs. ITO, WARD-1,, NAGAPATTINAM
What did the Tribunal hold?
The Tribunal condoned the delay in filing the appeal, finding sufficient cause. It restored the matter to the CIT(A) for fresh adjudication on merits, granting the assessee a final opportunity to present their case.
What were the facts?
The assessee deposited a large cash amount in their textile business. Upon failure to provide source documents, the AO treated it as unexplained money and imposed a penalty. The CIT(A) dismissed the appeal due to a significant delay in filing.
What were the issues?
Whether the delay in filing the appeal before the CIT(A) was justifiable and if the assessee should be granted an opportunity to present their case on merits.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI
Before: SHRI INTURI RAMA RAO & SHRI MANU KUMAR GIRI
आदेश / O R D E R
PER MANU KUMAR GIRI, JM:
The captioned online appeal filed by the Assessee is directed against the order of the Ld. Commissioner of Income Tax (Appeals), NFAC, Delhi, [CIT(A)] dated 22.01.2025 for Assessment Year 2015- 16. 2. The appellant is an individual engaged in the textile business under the trade name Karpakam Textiles who had deposited the cash amount of Rs. 1,28,15,000/- during the year under consideration. Upon failure of submission of necessary documents to prove the source of income, the AO assessed an amount of Rs.
ITA No 615/Chny/2026 (AY 2017-18) Singaravelmudaliar Ravindran Vs ITO W 1 :: 2 :: 1,28,15,000/- as unexplained money u/s 69A for concealment of particulars of income and imposed the penalty u/s 271(1)(c) of Rs. 43,43,118/-. 3. Being aggrieved with the penalty order passed by the AO, the assessee preferred an appeal before the Ld. CIT(A) sought quashing the penalty imposed by the AO for the reasons that there was no tax demand in the computation sheet and demand notice. However, the Ld.CIT(A), vide its order dated 22.01.2025 dismissed the appeal of the assessee on account of delay of 341 days in filing the appeal related to the issue under consideration and confirmed the order of AO. 4. Being aggrieved with the order passed by the Ld.CIT(A) in limine, the assessee preferred an appeal before this Tribunal and sought condonation of delay in filing appeal and an opportunity to file the relevant/necessary documents. 5. The ld. Departmental Representative (DR), on the other hand, supported the order of the ld. CIT(A) and prayed for dismissal of the appeal. 6. We have considered the rival submissions and perused the order of the ld. CIT(A). We find the reasons given for delayed filing of appeal a ‘sufficient cause’. We condone the delay in filing appeal. Further, in the interest of justice, we are of the view that the assessee should be granted a final opportunity to substantiate the issue under consideration on merits. Accordingly, the impugned order is set aside and the matter is restored to the file of the ld. CIT(A) for fresh adjudication on merits. The ld. CIT(A) shall afford the assessee a reasonable opportunity of being heard. The assessee is directed to diligently prosecute the penalty appeal and actively participate in the appellate proceedings.
ITA No 615/Chny/2026 (AY 2017-18) Singaravelmudaliar Ravindran Vs ITO W 1 :: 3 :: 7. In the result, appeal filed by the assessee is allowed for statistical purposes. Order pronounced in the open court on the 19th day of May 2026, in Chennai.
Sd/- Sd/- (इंतूरी रामा राव) (मनु कुमार िग�र) (INTURI RAMA RAO) (MANU KUMAR GIRI) लेखा सद*य/ACCOUNTANT MEMBER �या�यक सद*य/JUDICIAL MEMBER
चे�नई/Chennai, +दनांक/Dated: 19th May, 2026. SNDP, Sr. PS
आदेश क! ��त,ल-प अ.े-षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF
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