SATYABHAN,DHUMARI, ETAH vs. INCOME-TAX OFFICER, WARD 4(3)(1), ETAH, INCOME TAX OFFICE, RAILWAY ROAD, ETAH

ITA 422/AGR/2026Status: DisposedITAT Agra01 October 2026AY 2019-20206 pages
AI SummaryAllowed

What were the facts?

The assessee, Satyabhan, an ex-serviceman from a rural background, filed two appeals (ITA Nos. 422 and 430/Agr/2026) before the Income Tax Appellate Tribunal (ITAT), Agra Bench, for Assessment Year 2019-20. These appeals challenged orders dated 17.09.2025 passed by the Commissioner of Income Tax (Appeals), NFAC, Delhi. The CIT(A) had dismissed the assessee's appeals in limine, refusing to condone a delay of approximately 9 months and 7 months in filing the appeals before the CIT(A). The assessee's appeals before the ITAT were themselves delayed by 164 and 167 days. The assessee's explanation for the delay before the CIT(A) was that he was unaware of the assessment proceedings due to disputes with local villagers, and that any notices might have been received by locals without his knowledge. The ITAT noted that the assessee's appeals to the CIT(A) were filed on 22.01.2025 and 02.05.2025, respectively, against assessment and penalty orders dated 27.02.2024 and 09.08.2024.

What did the Tribunal hold?

The Tribunal held that the explanation provided by the assessee for the delay in filing appeals before the CIT(A) constituted a sufficient cause. The Tribunal was satisfied that the assessee's circumstances, including being from a rural background and an ex-serviceman, warranted condonation of the delay. The Tribunal cited the Supreme Court's decision in Sambhaji and Ors V Gangabai and Ors, emphasizing that the object of procedural rules and limitation periods is to advance the cause of justice. Consequently, the Tribunal condoned the delays of approximately 9 months and 7 months in filing the first appeals before the CIT(A). The Tribunal further set aside the impugned orders of the CIT(A) dated 17.09.2025 and restored the matters back to the file of the CIT(A) for fresh adjudication on merits. The Tribunal also directed the CIT(A) to ensure substantial compliance with the principles of natural justice. No specific issue was left undecided.

What were the issues?

1. Whether the learned CIT(A) erred in dismissing the assessee's appeals in limine by not condoning the delay in filing the appeals before him, thereby violating the principles of natural justice? (Question of law and fact, concerning Section 250 and Section 249(3) of the Income Tax Act, 1961). Assessee's Contention: The assessee argued that the delay in filing appeals before the CIT(A) was due to his unawareness of assessment proceedings, caused by local disputes, and that this constituted a sufficient cause for condonation. The assessee also contended that the CIT(A) passed orders without affording a proper opportunity of hearing. The assessee relied on the Supreme Court judgment in Sambhaji and Ors V Gangabai and Ors to support the principle that procedural rules are meant to advance justice. Revenue's Contention: The revenue did not explicitly record any contentions in the judgment regarding the delay condonation or the merits of the case before the CIT(A). The judgment states that the learned Sr. DR for the respondent revenue was heard, but their specific arguments are not detailed.

Which sections of the Income-tax Act were involved?

Section 250,Section 249(2),Section 249(3),Section 270A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AGRA(DB

Before: SUNIL KUMAR SINGHBRAJESH KUMAR SINGH

For Appellant: Shri Deependra Mohan, CA
Hearing: 21.07.2026Pronounced: 21.07.2026

PER:BRAJESH KUMAR SINGH, A.M.

These two appeals are directed against the impugned orders both dated 17.09.2025 passed in appeal No NFAC/2018-19/10426286 and NFAC/2018-19/10491644 by the Commissioner of Income Tax (Appeals), NFAC, Delhi [hereinafter referred to as the CIT(A)], u/s. 250 of the Income

ITA No. 422 and 430/Agr/2026

Tax Act, 1961 (hereinafter referred to as the “Act”) for the A.Y. 2019-20, wherein Ld. CIT (A) has dismissed assessee’s appeals in limine by not condoning the delay of about 9 months and 7 months in filing the respective appeals before the learned CIT(A). Since both the appeals are inter related to the same assessee, they are being disposed by this c

The order continues below.

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