What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal before the CIT(A) subject to the payment of a reasonable cost of Rs. 10,000/-. The CIT(A) was directed to decide the appeal afresh on merits after the cost is deposited.

The assessee's appeal before the CIT(A) was dismissed in limine for being barred by limitation by 540 days. The assessee cited internal disputes and lack of awareness as reasons for the delay.

What were the issues?

Whether the delay in filing the appeal before the CIT(A) was sufficiently explained and if the appeal should be decided on merits.

Superfine Hotels Pvt Ltd, Nehru… vs ACIT | s.250 | ITAT Jaipur 2026

Income Tax Appellate Tribunal, JAIPUR BENCHES, “B” BENCH, JAIPUR

Hearing: 24.03.2026Pronounced: 18.05.2026

P a g e | 1 ITA No.1376/JPR/2025 Superfine Hotels Pvt. Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “B” BENCH, JAIPUR BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER & SHRI RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER ITA No. 1376/JPR/2025 (Assessment Year:2016-17) Superfine Hotels Pvt. Ltd. Vs. ACIT D 29 Ashiyana Apartment, Circle 6 Shanti Path Tilak Nagar Jaipur 302004 �थायीलेखासं./जीआइआरसं./PAN/GIR No: AALCS0201P Appellant .. Respondent Appellant by : Sh. S.L. Poddar, Adv Respondent by : Sh. Gaurav Awasthi, JCIT Date of Hearing 24.03.2026 Date of Pronouncement 18.05.2026 O R D E R Per Sanjay Garg, Judicial Member: The present appeal has been preferred by the assessee against the orders of National Faceless Appeal Centre (NFAC)/Ld. Commissioner of Income Tax (Appeals)(hereinafter referred to as “Ld. CIT(A)”)dated 01.10.2025, passed u/s 250 of the Income Tax Act,1961 (hereinafter referred to as “the Act”).

The assessee in this appeal is aggrieved by the action of the Ld. CIT(A) in confirming the addition made by the Assessing Officer of

P a g e | 2 ITA No.1376/JPR/2025 Superfine Hotels Pvt. Ltd. Rs.2,68,883/- on account of unexplained unsecured loans and further addition of Rs.64,48,048/- on account of 8% profit rate on total receipts shown in the profit and loss account of the assessee company in respect of its hotel business.

At the outset, the learned counsel for the assessee has invited our attention to the impugned order of the Ld. CIT(A) to submit that the Ld. CIT(A) has dismissed the appeal of the assessee in limine, holding it to be barred by limitation by 540 days. The Ld. AR of the assessee has submitted that a separate application for condonation of delay was filed before the Ld. CIT(A), wherein it was pleaded that there was a dispute between the old Directors and new Directors of the assessee company; that there was no responsible person to check the emails etc., in the name of the assessee, and that the assessee was not aware of the passing of the impugned assessment order. It was only when the demand notice was received, that the assessee came to know of the passing of the impugned assessment order. The Learned Counsel has submitted that the assessee has a fair case on merits. He, therefore, has submitted that the assessee may be given an opportunity to present its case before the Ld. CIT(A) so that the same may be decided on merits.

The Ld. DR, however, has strongly relied on the order of the Ld. CIT(A) and has contended that there is no sufficient cause for condonation of delay before the Ld. CIT(A). Therefore, the Ld. CIT(A) has rightly dismissed the appeal of the assessee.

P a g e | 3 ITA No.1376/JPR/2025 Superfine Hotels Pvt. Ltd. 5. We have heard the rival contentions and gone through the record. In this case, though there was a long delay of 540 days in filing the appeal before the Ld. CIT(A), however, the assessee has explained the reasons for such delay. The learned counsel has submitted that the assessee has a fair case on merits.

In our view, the interest of justice will be well served if the assessee is given an opportunity to present its case before the Ld. CIT(A);however, subject to imposition of a reasonable cost, which we assess at Rs.10,000/-. The assessee will deposit the aforesaid amount of Rs.10,000/- in the Prime Minister’s Relief Fund within 60 days of the receipt of copy of this order and will produce the evidence of such deposits before the Ld. CIT(A). Thereafter, the Ld. CIT(A) will decide the appeal of the assessee afresh. The delay in filing the appeal before the Ld. CIT(A) is condoned subject to the deposit of the cost amount.

With the above observations, the appeal of the assessee is treated as allowed for statistical purposes.

Order is pronounced under provision of Rule 34 of ITAT Rules, 1963 on 18/05/2026.

Sd/- Sd/- (Ratnesh Nandan Sahay) (Sanjay Garg) Accountant Member Judicial Member Dated 18.05.2026 Mittali, Sr. PS

P a g e | 4 ITA No.1376/JPR/2025 Superfine Hotels Pvt. Ltd. Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT By Order,

Asst. Registrar ITAT, Jaipur

SUPERFINE HOTELS PVT LTD ,NEHRU SHANKAR MARG vs. ACIT CIRCLE-6, JAIPUR, JAIPUR

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