RAMANA REDDY,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 3(1)(1), BENGALURU

ITA 1812/BANG/2026Status: DisposedITAT Bangalore09 October 2026AY 2017-183 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the reason advanced by the assessee for the delay in filing the appeal does not constitute sufficient cause. The Tribunal perused the material on record and heard the rival contentions. It was of the opinion that the delay should not be condoned. Consequently, the Tribunal dismissed the appeal of the assessee. The operative direction is the dismissal of the appeal. No issue was expressly left undecided, as the primary issue of condonation of delay was decided against the assessee, leading to the dismissal of the appeal on procedural grounds.

What were the facts?

The assessee, Ramana Reddy, filed an appeal before the Income Tax Appellate Tribunal (ITAT), Bangalore Bench, against the order of the Commissioner of Income Tax (Appeal) dated March 10, 2025, for the Assessment Year 2017-18. The appeal was filed with a delay of 332 days. The assessee sought condonation of this delay, explaining that they were under the bonafide belief that the assessment order had reached finality after paying the estimated additions and corresponding tax demand. However, upon initiation of penalty proceedings under Section 270A of the Act on March 26, 2026, the assessee realized the penalty stemmed from the quantum addition that was not challenged before higher authorities. The assessee contended the delay was not intentional but due to the belief that paying the tax demand would conclude proceedings.

What were the issues?

1. Whether the delay of 332 days in filing the appeal by the assessee is to be condoned, considering the reasons provided. Assessee's contention: The assessee argued that the delay was not intentional or deliberate but arose from a bonafide belief that the assessment proceedings were concluded upon payment of the tax demand. The initiation of penalty proceedings under Section 270A brought to their notice the need to challenge the quantum additions, leading to the delayed appeal. Revenue's contention: The Ld. DR objected to the condonation of the delay, implying that the reasons provided by the assessee did not constitute sufficient cause.

Which sections of the Income-tax Act were involved?

Section 270A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI BALAKRISHNAN S & SHRI SOUNDARARAJAN K.

For Respondent: Shri. Pradeep S - Addl. CIT
Pronounced: 09.10.2026

PER SHRI BALAKRISHNAN S, ACCOUNTANT MEMBER:

This appeal is filed by the assessee against the order of Ld. Commissioner of Income Tax (Appeal) vide DIN: ITBA/NFAC/250/2024-25/1074282920(1) dated 10-Mar-2025 for the Assessment Year 2017-18. 2. At the outset, it is noticed that assessee has filed the appeal with a delay of 332 days. The assessee has filed a petition for condonation of delay along with affidavit.

ITA 1

The order continues below.

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