KOMMARAGUNTA MANJULA,CHITTOOR vs. ITO, WARD-1, CHITTOOR

आयकर अपील�य अ�धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ A ‘ 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. 417/Hyd/2026 (िनधा�रण वष�/Assessment Year: 2017-18) Smt. Kommaragunta Vs. Income Tax Officer Manjula Ward – 1 CHITTOOR Chittoor PAN:CTXPM5650A (Appellant) (Respondent) िनधा�रती �ारा/Assessee by: Mr. Yeshwant E, Tax Consultant राज� व �ारा/Revenue by: Shri G.V. Pavan Kumar, Sr.AR सुनवाई की तारीख/Date of hearing: 27/04/2026 घोषणा की तारीख/Pronouncement: 29/04/2026 आदेश/ORDER Per Madhusudan Sawdia, A.M.:

This appeal is filed by Smt. Kommaragunta Manjula (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”) dated 29.01.2026 for the A.Y. 2017-18. 2. The assessee has raised the following grounds of appeal:

3 4. Aggrieved by the order of the Ld. CIT (A), the assessee is in appeal before this Tribunal. The Learned Authorized Representative (“Ld. AR”) submitted that the assessee is a small farmer and also works as a business correspondent in very small village. It was submitted that the assessee has very limited understanding of income tax laws, notices, and procedural timelines. Due to lack of awareness, absence of professional guidance, and non-availability of tax consultants in the village at the relevant time, the assessee could not file the appeal within the prescribed period. The Ld. AR further submitted that the assessee came to know about the assessment order passed by the Ld. AO only when recovery proceedings were initiated against him, and immediately thereafter, the assessee took steps to file the appeal before the Ld. CIT(A). It was thus contended that the delay of 276 days was neither intentional nor attributable to any mala fide conduct but occurred due to genuine hardship and lack of knowledge. Accordingly, it was prayed that the delay be condoned in the interest of justice. The Ld. AR also submitted that since the appeal could not be effectively prosecuted before the Ld. CIT(A), one more opportunity may be granted to the assessee by restoring the matter to the file of the Ld. CIT(A) for adjudication on merits. 5. Per contra, the Learned Departmental Representative (“Ld. DR”) did not raise any serious objection to the condonation of delay and fairly submitted that the matter may be restored to the file of the Ld. CIT(A) with suitable directions. 6. We have given our thoughtful consideration to the rival submissions and perused the material on record. It is a

4 settled principle that when substantial justice and technical considerations are pitted against each other, the cause of substantial justice deserves to prevail. In the present case, considering the background of the assessee, the explanation that the assessee became aware of the assessment order only upon initiation of recovery proceedings, and in the absence of any material to suggest deliberate inaction or mala fide intent, we are inclined to accept the explanation offered. Accordingly, in the interest of substantial justice, we condone the delay in filing the appeal before the Ld. CIT(A). We further observe that the appeal of the assessee could not be effectively prosecuted before the Ld. CIT(A) on merits. Therefore, the impugned order of the Ld. CIT(A) is set aside and the matter is restored to his file 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 is directed to cooperate in the appellate proceedings and shall not seek unnecessary adjournments. The assessee is at liberty to file all relevant documents and explanations in support of his case before the Ld. CIT(A). 7. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the Open Court on 29th April, 2026. Sd/- Sd/- (RAVISH SOOD) (MADHUSUDAN SAWDIA) JUDICIAL MEMBER ACCOUNTANT MEMBER Hyderabad, dated 29th April, 2026. Vinodan/sps

5 Copy to: S.No Addresses 1 Smt. KOMMARAGUNTA MANJULA GUDYANAM PALLI PENUMURU MANDAL , CHITTOOR 517126 ,Andhra Pradesh 2 Income Tax Officer Ward-1 Chittoor 3 Pr. CIT - Tirupati 4 DR, ITAT Hyderabad Benches 5 Guard File By Order VADREVU Digitally signed by VADREVU PRASADA PRASADA RAO Date: 2026.04.29 RAO 15:19:38 +05'30'