PATELS GREEN FRONT ASSOCIATION,HYDERABAD vs. ITO, WARD -11(1), HYDERABAD

आयकर अपील�य अ�धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B‘ Bench, Hyderabad �ी रिवश सूद,�ाियक सद� एवं �ी मधुसूदन साविड़या लेखा सद� सम� | Before Shri Ravish Sood, Judicial Member A N D Shri Madhusudan Sawdia, Accountant Member आ.अपी.सं /ITA No. 147/Hyd/2026 (िनधा�रण वष�/Assessment Year: 2020-21) Patels Green Front Vs. ITO Association, Hyderabad Ward 11(1) PAN: AAHAP4277E Hyderabad (Appellant) (Respondent) िनधा�रती �ारा/Assessee by: CA Abhiroop Bhargav राज� व �ारा/Revenue by: Smt.Uppaluri Meena, Sr. AR सुनवाई की तारीख/Date of hearing: 11/06/2026 घोषणा की तारीख/Pronouncement: 17/06/2026 आदेश/ORDER Per Madhusudan Sawdia, A.M.:

This appeal is filed by Patels Green Front Association (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC) (“Ld. CIT(A)”) dated 23.11.2025 for the A.Y. 2020-21. 2. The assessee has raised the following grounds of appeal: “1. That on facts and circumstances of the case and in law, the Order u/s 143 rws 144B as well as the Order u/s 250 of the Income-tax Act, 1961 (‘Act’) is bad in law;

assessment proceedings. However, the external professionals failed to properly advise the assessee regarding the further course of action after passing of the assessment order. Consequently, the members of the Managing Committee were not aware of the procedure and the limitation period prescribed for filing the appeal before the Ld. CIT(A). The Ld. AR further submitted that during the relevant period there was a change in the members of the Managing Committee and the newly constituted Managing Committee, immediately upon becoming aware of the assessment order and the appellate remedy available under the Act, took prompt steps to file the appeal before the Ld. CIT(A). He submitted that the delay was neither deliberate nor attributable to any mala fide intention on the part of the assessee. Accordingly, he prayed that the delay in filing the appeal before the Ld. CIT(A) may be condoned and the matter may be restored to the file of the Ld. CIT(A) for adjudication on merits. 5. Per contra, the Learned Departmental Representative (“Ld. DR”) fairly submitted that the Revenue has no serious objection if the delay is condoned and the matter is restored to the file of the Ld. CIT(A) for adjudication on merits, provided the assessee extends full cooperation during the appellate proceedings and does not seek unnecessary adjournments. 6. We have heard the rival submissions and perused the material available on record. We find that the delay of 159 days in filing the appeal before the Ld. CIT(A) has been explained by the assessee on account of lack of awareness of the statutory provisions, dependence upon external

professionals, and change in the constitution of the Managing Committee during the relevant period. We further find that the explanation furnished by the assessee has not been found to be false or lacking in bona fides. We also find that the Hon’ble Supreme Court, in the case of Vidya Shankar Jaiswal v. CIT (174 taxmann.com 21), has held that a justice-oriented and liberal approach should be adopted while considering applications for condonation of delay. Considering the totality of the facts and circumstances of the case and in the interest of substantial justice, we are satisfied that the assessee was prevented by sufficient cause from filing the appeal within the prescribed period. Accordingly, the delay of 159 days in filing the appeal before the Ld. CIT(A) is condoned. 7. Since the Ld. CIT(A) has dismissed the appeal of the assessee solely on the ground of limitation without adjudicating the issues raised by the assessee on merits, we deem it appropriate to set aside the impugned order and restore the matter to the file of the Ld. CIT(A) with a direction to adjudicate the appeal afresh on merits in accordance with law after providing adequate opportunity of being heard to the assessee. The assessee shall be at liberty to file all supporting documents, evidences and submissions in support of its claims before the Ld. CIT(A). At the same time, the assessee is directed to extend full cooperation in the appellate proceedings and shall not seek unnecessary adjournments. In the event of any non-cooperation on the part of the assessee, the Ld. CIT(A) shall be at liberty to proceed in accordance with law.