JEEVIKA WOMEN AGRI PRODUCER COMPANY LIMITED,KHAGARIA, BIHAR vs. ITO WARD 3(1), PURNIA

ITA 504/PAT/2026Status: DisposedITAT Patna16 October 2026AY 2019-203 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the assessee had sufficient cause for not filing the appeal within the statutory time period before the Ld. CIT(A). Consequently, the delay in filing the appeal before the Ld. CIT(A) was condoned. The Tribunal directed the Ld. CIT(A) to adjudicate the appeal on its merits after providing the assessee with a reasonable opportunity of hearing. The issue regarding the denial of deduction under Section 80PA was not decided on merits by the ITAT, as the matter was remanded back to the Ld. CIT(A).

What were the facts?

The assessee, Jeevika Women Agri Producer Company Ltd., filed its return of income for Assessment Year 2019-20, claiming a deduction of Rs. 16,54,854/- under Section 80PA. The Centralized Processing Centre (CPC) denied this deduction, stating the return was filed after the due date or did not meet the specified conditions for Section 80PA. The assessee appealed to the Ld. CIT(A), who dismissed the appeal due to a delay of 2107 days, finding no sufficient cause. The assessee then filed an appeal before the Income Tax Appellate Tribunal (ITAT).

What were the issues?

1. Whether the assessee had sufficient cause for the delay in filing the appeal before the Ld. CIT(A), thereby warranting condonation of the delay under Section 250 of the Income Tax Act, 1961? Assessee's Contention: The assessee argued that there was no actual delay as it was pursuing remedies before the CPC through rectification applications and grievance petitions. Its latest grievance petition was rejected on 29.04.2026, and the appeal was filed on 16.05.2026, which it considered timely. Revenue's Contention: The Ld. DR relied on the orders of the lower authorities, implying no sufficient cause for the delay was established.

Which sections of the Income-tax Act were involved?

Section 80PA,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH: PATNA

Before: Shri Pradip Kumar Choubey & Shri Gopalan Gurusamy

Per Gopalan Gurusamy, AM:

This is the appeal preferred by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals)-Addl/JCIT(A)-3, Ahmedabad (hereinafter referred to as the “Ld. CIT(A)”] passed u/s 250

2 Assessment Years: 2019-20 Jeevika Women Agri Producer Company Ltd. of the Act dated 03.07.2026 for the AY 2019-20 vide Appeal No. Addl/JCIT(A)-3, Ahmedabad/ 10029/ 2018-19. 2. Brief facts on record reveals that the assessee filed its return of income for AY 2019-20 returning total income of Rs. 7,730/- after claiming deduction u/s 80PA of Rs. 16,54,854/-. The C

The order continues below.

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