ALAGIRI ANJUGASELVI,CHENNAI vs. ITO, NON CORP WARD 3(1), CHENNAI

ITA 3458/CHNY/2026Status: DisposedITAT Chennai05 October 2026AY 2013-145 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee failed to establish a sufficient and reasonable cause for the substantial delay of 285 days in filing the appeal. While the assessee cited involvement in various proceedings and the time required for collecting evidence, these reasons were neither substantiated with cogent material nor demonstrated any circumstance preventing timely filing. Furthermore, the assessee's conduct before the Tribunal, including repeated non-appearance on scheduled hearing dates (18.08.2026, 21.08.2026, and 27.08.2026) without any explanation or request for adjournment, did not support a plea of bona fide and diligent prosecution. Consequently, the delay was not condoned, and the appeal was dismissed as barred by limitation. The Tribunal found no infirmity in the orders of the lower authorities, as the grounds raised remained unsupported by evidence or submissions, and the factual findings of the AO and CIT(A) were uncontroverted.

What were the facts?

The assessee, Alagiri Anjugaselvi, is an individual who did not file her return of income for Assessment Year 2013-14. The Assessing Officer (AO) re-opened the assessment under Section 147 of the Income-tax Act, 1961, based on information of cash deposits totaling Rs. 1,82,75,000/- in her bank account. The assessee filed a return admitting a total income of Rs. 11,24,260/-. The AO completed the assessment under Section 143(3) r.w.s. 147, making additions of Rs. 10,52,500/- as unexplained credit card payments under Section 69C and Rs. 1,82,75,000/- as unexplained deposits under Section 69A. The assessee appealed to the Commissioner of Income Tax (Appeals) [CIT(A)], who confirmed the AO's order. The assessee then filed an appeal before the Income Tax Appellate Tribunal (ITAT), which was filed with a delay of 285 days. The ITAT noted that the assessee did not appear for hearings on multiple occasions.

What were the issues?

1. Whether the delay of 285 days in filing the appeal by the assessee before the Tribunal is to be condoned, considering the reasons provided in the affidavit and the assessee's conduct. Assessee's Contention (implied by affidavit): The assessee contended that the delay was due to continuous engagement in assessment, prosecution, and compounding proceedings across multiple assessment years, and the necessity to collect voluminous banking records and supporting evidence to present an effective appeal. This involved obtaining certified records, consulting tax professionals, and compiling documentary evidence for bank transactions and credit card payments. Revenue's Contention: The Revenue argued that the assessee was negligent in participating in proceedings before the authorities, including the Tribunal, and therefore prayed for the dismissal of the appeal. The Revenue supported the orders of the lower authorities.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 148,Section 69A,Section 69C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘A’ BENCH, CHENNAI

Before: SHRI S.S. VISWANETHRA RAVI & SHRI S. R. RAGHUNATHA

For Respondent: Ms. Anshu Sharawat, Addl. CIT
Hearing: 27.08.2026Pronounced: 05.10.2026

PER S.R. RAGHUNATHA, AM : This appeal has been preferred by the Assessee against the order passed by the Learned Commissioner of Income Tax, Appeal, CIT(Appeals), Chennai-18, [hereinafter referred to as “the Ld. CIT(A)”], dated 23.06.2025, arising from the assessment order dated 05.10.2019 for the Assessment Year (AY) 2013-14 passed by the Assessing Officer, Non Corporate Ward-3(1), Chennai [hereinafter referred to as “t

The order continues below.

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