RAVICHANDRAN SATHYA,KARUR vs. ITO, WARD 1 KARUR/, KARUR

ITA 3866/CHNY/2026Status: DisposedITAT Chennai23 September 2026AY 2020-213 pages
AI SummaryRemanded

What did the Tribunal hold?

The ITAT, considering the submissions of both the assessee's AR and the Revenue's DR, and in the interest of justice, decided to accept the assessee's prayer. The Tribunal acknowledged the material evidence at page numbers 46 and 47. Consequently, the ITAT set aside the order of the CIT(A) and remanded the matter back to the file of the CIT(A) for fresh consideration. The assessee was granted liberty to file any further evidence in support of their claim. The grounds raised by the assessee were allowed for statistical purposes. The ITAT did not decide on the merits of the original appeal before the CIT(A), as the primary issue was the condonation of delay.

What were the facts?

The assessee, Ravichandran Sathya, filed an appeal before the Income Tax Appellate Tribunal (ITAT), Chennai, against the order dated 22.05.2026 passed by the Commissioner of Income Tax (Appeals) (CIT(A)) for the assessment year 2020-21. The appeal before the CIT(A) was filed with a delay of 440 days. The CIT(A) had dismissed the appeal, holding that the assessee had not provided appropriate reasons for the delay and that the submitted screenshots of the e-filing portal for 2017-18 were irrelevant to the present case. The assessee's authorized representative (AR) drew the Tribunal's attention to specific pages of the appeal paper book, stating they supported the assessee's case before the CIT(A).

What were the issues?

1. Whether the ITAT should condone the delay of 440 days in filing the appeal before the CIT(A) in the interest of justice, considering the material evidence presented by the assessee. (Question of mixed law and fact, turning on the principles of condonation of delay and sufficient cause under the Income Tax Act, 1961). Assessee's Contention: The assessee's AR argued that the evidence at pages 46 and 47 of the appeal paper book supported the assessee's case before the CIT(A) and prayed for the matter to be remanded to the CIT(A) with a direction to condone the delay of 440 days in the interest of justice. Revenue's Contention: The Revenue's Additional Commissioner of Income Tax (Addl. CIT) reported no objection to the assessee's prayer.

AI-generated summary — verify with the full judgment below

आयकरअपीलीयअिधकरण, ’ए’ "ायपीठ,चे"ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ीयस यस िव"ने" रिव, "ाियक सद" एवं सु"ीपदमावती यस, लेखा सद"के सम" BEFORE SHRI SS VISWANETHRA RAVI, JUDICIAL MEMBER AND MS. PADMAVATHY.S, ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.No. 3866/Chny/2026 िनधा"रणवष"/Assessment Year: 2020-21 4/154A, Mangamma salai, Kandiyur, Ward-1, Vathiyam, Karur, Karur. Tamil Nadu-639105. [PAN: GHPPS7125Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ"कीओरसे/ Appellant by : Mr. G. Sriram, CA ""थ"कीओरसे/ Respondent by Mr. Anshu Sharawat, Addl. CIT : सुनवाईकीतारीख/Date of hearing : 15.09.2026 घोषणाकीतारीख /Date of Pronouncement 23.09.2026 : आदेश /O R D E RJ PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appeal filed by the assessee is directed against the order dated 22.05.2026 passed by the ld. Commissioner of Income Tax (Appeals), Delhi for the assessment year 2020-21. 2. At the outset, it is noted that the assessee filed an appeal before the Ld. CIT(A) with a delay of 440 days. According to the Ld. CIT(A), the assessee has not given any appropriate reasons for delay in filing the appeal and held that screen shots of the e-filing porta

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