What did the Tribunal hold?

The Tribunal condoned the delay, finding the assessee's reasons reasonable and applying a liberal approach to advance substantial justice. The matter was remitted back to the FAA for adjudication on merits.

The assessee's appeal was dismissed in limine by the First Appellate Authority (FAA) due to a 4-month delay without condoning it. The assessee, a rural cooperative credit society, cited difficulties with faceless proceedings and lack of local professional assistance.

What were the issues?

Whether the delay in filing the appeal before the FAA was sufficiently explained and should be condoned. Whether the FAA erred in dismissing the appeal without adjudicating on merits.

K 1368 Vedachinnanur Pacb… vs ITO | ITAT Chennai 2026

Income Tax Appellate Tribunal, ‘D’ BENCH, CHENNAI

Before: SHRI GEORGE GEORGE KAND MS PADMAVATHY S

Hearing: 21.04.2026Pronounced: 22.04.2026

आदेश/ O R D E R PER GEORGE GEORGE K, VICE PRESIDENT: This appeal filed by the assessee is directed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, dated 19.12.2025 passed under section 250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2015-16.

:- 2 -: ITA No.1122/Chny/2026 2. At the very outset, we note that the First Appellate Authority (FAA) has dismissed the appeal in limine without adjudicating the issues on merits. The FAA had not condoned the delay of 4 months in filing the appeal before him. The FAA observed that in Form No. 35, the assessee had stated the reason for delay, which has been extracted in the impugned order at para 6.6. However, the FAA dismissed the appeal of the assessee, on the ground that the assessee failed to establish sufficient cause for condonation of delay

Before us, the Ld. AR submitted that the assessee, being a Primary Agricultural Co-operative Credit Society functioning in a rural area with limited administrative and technical infrastructure, faced genuine difficulty in complying with faceless appellate proceedings and electronic systems, as its office bearers are not well-versed with such procedures, resulting in inability to properly access and understand communications issued through the Income Tax portal. It is further submitted that due to the lack of immediate availability of professional assistance in the locality, considerable time was taken in identifying and consulting an appropriate professional and in compiling the necessary records. The Ld.AR placed reliance on the decision of the Hon’ble Supreme Court in the

:- 3 -: ITA No.1122/Chny/2026 case of Collector, Land Acquisition v. Mst. Katiji, wherein it has been held that a liberal approach should be adopted while considering condonation of delay.

The Ld.DR supported the order of the FAA.

We have heard the rival submissions and perused the material on record. On perusing the order of FAA, we note that the assessee had stated the reason for delay in filing the appeal before him. However, the FAA dismissed the appeal of the assessee, on the ground that the assessee failed to establish sufficient cause for condonation of delay. The Ld.AR submitted that the assessee, being a Primary Agricultural Co-operative Credit Society functioning in a rural area, the office bearers of the assessee were not well-versed with faceless proceedings and electronic compliance systems, which resulted in difficulty in accepting and understanding the communications issued through the Income Tax Portal. The Ld.AR further submitted that due to non-availability of immediate professional assistance in the locality, considerable time was taken in identifying and consulting an appropriate professional and in compiling the necessary records. Considering the facts and circumstances of the case, and in view of the principles laid down by the Hon’ble Supreme Court in Collector, Land Acquisition v. Mst.

:- 4 -: ITA No.1122/Chny/2026 Katiji reported in 167 ITR 471, (1987), wherein it has been held that a liberal approach should be adopted in matters relating to condonation of delay to advance substantial justice, we are of the view that the reasons cited by assessee before FAA for belated filing of appeal before FAA seems quite reasonable and hence, we condone the delay in filing the appeal before FAA and also direct him to admit the issue on merits. Accordingly, we set aside the order of FAA and remit the matter back to his file for adjudicating the issue on merits. It is ordered accordingly.

In the result, the assessee filed by the assessee is allowed for statistical purposes.

Order pronounced in the open court on 22nd April, 2026 at Chennai.

Sd/- Sd/- (प�मावती एस) (जॉज� जॉज� के) (PADMAVATHY S) (GEORGE GEORGE K) लेखा सद�य/ACCOUNTANT MEMBER उपा�य� /VICE PRESIDENT चे�ई/Chennai, �दनांक/Dated, the 22nd April, 2026 RSR आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��यथ�/Respondent 3. आयकर आयु�त /CIT, Coimbatore 4. �वभागीय ��त�न�ध/DR By Order 5. गाड� फाईल/GF. Digitally signed by REKHA REKHA SENTHIL RAJ SENTHIL RAJ Date: 2026.04.28 10:20:10 +05'30'

K 1368 VEDACHINNANUR PACB LIMITED,ERODE vs. THE INCOMETAX OFFICER, WARD 2(1), ERODE

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