RONCH POLYMERS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX CIRCLE - 8(1)(1), MUMBAI

ITA 1533/MUM/2026Status: DisposedITAT Mumbai18 May 2026AY 2011-20126 pages
AI SummaryAllowed

What were the facts?

The assessee filed a rectification application under Section 154 of the Income-tax Act, 1961, which was rejected by the Assessing Officer (AO) and the Commissioner of Income Tax (Appeals) [CIT(A)] as time-barred. The assessee claimed they were unaware of the intimation order until recovery proceedings were initiated.

What did the Tribunal hold?

The Tribunal held that the limitation period for filing a rectification application should be counted from the date of communication of the order, not the date of the order itself. Following the jurisdictional High Court's decision, the Tribunal condoned the delay and set aside the CIT(A)'s order.

What were the issues?

Whether the rectification application was time-barred, considering the date of communication versus the date of the order. Whether the CIT(A) erred in dismissing the appeal on grounds of limitation for a rectification application.

Which sections of the Income-tax Act were involved?

Section 154,Section 143(1),Section 154(7)

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
IN THE INCOME-TAX APPELLATE TRIBUNAL, MUMBAI “D” BENCH, MUMBAI BEFORE SHRI SANDEEP GOSIAN, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER Ronch Polymers Private Ltd. vs. Dy. Commissioner of Income Tax Circle -8(1)(1) Incorp Advisory Services Private Limited, 2nd Floor, Geeta Building, Aayakar Bhawan, Mumbai-400021. Sion Circle, Next to IIP Petrol Pump, Mumbai-400022. PAN/GIR No: AAACR4924P (Appellant) (Respondent) Assessee by Mr. Subham Shah Revenue by Shri Umashankar Prasad, (CIT-DR) & Shri Annavaram Kosuri (SR AR) Date of Hearing 18.05.2026 Date of Pronouncement 12.08.2026

O R D E R PER BIJYANANDA PRUSETH, AM:

This appeal filed by the assessee emanates from the order passed under section 250 of the Income-tax Act, 1961 (in short, ‘Act’) by the Commissioner of Income Tax, Appeal ADDL/JCIT, Agra [in short, ‘CIT(A)’], dated 26.11.2025 for the assessment year (AY) 2011-12. 2. The grounds of appeal raised by the assessee are as under:

“Ground 1 - On given facts, circumstances and provisions of the law, the Ld. CIT(A) erred in dismissing the appeal on the grounds that the rectification application of the assessee was time-barred. Such dismissal of the appeal is bad

The order continues below.

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