PERUMAL CHANDIRAMANI,SALEM vs. ITO, WARD-1(1), SALEM

आदेश/O R D E R

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order dated 18.12.2025 passed by the ld. Commissioner of Income Tax (Appeals)/ NFAC, Delhi [‘ld.CIT(A)’ in short] for Assessment Year 2018- 19.

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making additions on account of variation in respect of incomes from

business or profession, unexplained investment u/s. 69A of the Income-

tax Act, 1961 [‘the Act’ in short] to an extent of Rs.8,68,439/- and

Rs.1,05,44,555/- respectively, vide his order dated 12.02.2024 passed u/s.

147 r.w.s. 144 and 144B of the Act, against which the assessee preferred

an appeal before the ld.CIT(A) with a delay of 370 days. The ld.CIT(A)

did not accept the reasons explained by the assessee, that the assessee

due to lack of technical knowledge and non-receipt of notices on the

Income-tax Portal, the ld.CIT(A) rejected the reasons explained by the

assessee vide his findings at Para 5.3 to 5.8 of the impugned order.

the ld.CIT(A) and prayed to remand the matter to the file of the ld.CIT(A)

for a fresh consideration of delay condonation petition.

impose cost if this Tribunal remands the matter to the file of the ld.CIT(A).

and circumstances of the case, we note that the addition made by the AO

requires assistance from the assessee and admittedly there was no

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representation before the ld.CIT(A) due to rejection of delay condonation

petition. We find force in the arguments of ld.AR that the assessee has a

fair case of succeeding before the ld.CIT(A) in case one opportunity is

given in remanding the matter to the file of the ld.CIT(A) with a direction to

consider the delay condonation petition and condone the delay.

Accordingly, we are of the considered view that the ld.CIT(A) is directed

to consider the delay condonation petition and condone the delay and

adjudicate the issues on merits. The assessee is liberty to file evidences,

if any, in support of his claim. The assessee shall appear before the

ld.CIT(A) in compliance to the notices issued therein. Thus, grounds

raised by the assessee are allowed for statistical purposes.

purposes. Order pronounced on 29th April, 2026 at Chennai.

Sd/- Sd/- (S.R. RAGHUNATHA) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER Chennai, Dated : 29.04.2026 JPV आदेशकी'ितिलिपअ.ेिषत/Copy to: 1. अपीलाथ&/Appellant, 2.'(थ&/ Respondent,

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PRASANNA Digitally signed by PRASANNA VANI JETTY VANI JETTY Date: 2026.05.04 10:51:05 +05'30'