The Principal Commissioner of Income tax 1 vs. The Electronics Corporation of Tamilnadu Limited

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TCA/186/2025HC Madras25 September 2025Bench: Honourable The CHIEF JUSTICE4 pages
AI SummaryDismissed

What did the High Court hold?

The High Court held that the first proposed question of law, concerning the correctness of the Tribunal's view in rejecting the application for condonation of delay, did not survive. The Court found that the Tribunal had considered the cause shown by the Revenue and concluded, as a finding of fact, that no sufficient cause was demonstrated. The appeal was filed on 12.01.2024, and even after excluding the period from 15.03.2020 to 28.02.2022 due to the Covid-19 pandemic, the delay was 503 days. As no sufficient cause was shown for this delay, the High Court found no merit in the proposed question of law. Consequently, the second proposed question of law was rendered unnecessary. The appeal was dismissed.

What were the facts?

This case involves an appeal filed by the Principal Commissioner of Income Tax-1, Chennai (Revenue) against an order of the Income Tax Appellate Tribunal (ITAT), Madras “C” Bench. The appeal is preferred under Section 260A of the Income-tax Act, 1961. The Revenue sought to challenge the ITAT's decision regarding the condonation of delay in filing an appeal before it. The ITAT had rejected the Revenue's application for condonation of delay, finding that no sufficient cause was shown. The Revenue's appeal before the High Court was filed on 12.01.2024, and even after excluding the period from 15.03.2020 to 28.02.2022 due to the Covid-19 pandemic, the appeal was found to be delayed by 503 days.

What were the issues?

1. Whether the High Court was correct in rejecting the Revenue's application for condonation of delay in filing an appeal before the Income Tax Appellate Tribunal, thereby not considering the substantive appeal on merits. This issue turns on the interpretation and application of principles governing condonation of delay, particularly in light of the Covid-19 pandemic period. The Revenue contended that the delay, even after exclusion of the pandemic period, was substantial and that the Tribunal erred in not finding sufficient cause. The Revenue argued that the Tribunal's view in rejecting the condonation application was incorrect. The judgment does not record any specific arguments from the respondent assessee, The Electronics Corporation of Tamilnadu Limited, on this issue.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

T.C.A.No.186 of 2025 IN THE HIGH COURT OF JUDICATURE AT MADRAS DATED: 25.09.2025 CORAM : THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE G.ARUL MURUGAN T.C.A.No.186 of 2025 The Principal Commissioner of Income tax-1, Chennai-600 034. Appellant Vs The Electronics Corporation of Tamilnadu Limited, No.692, MHU Complex, 2nd Floor, Anna Salai, Nandanam, Chennai-600 035. Respondent PRAYER

: Appeal filed under Section 260A of the Income-tax Act, 1961 against the order of the Income Tax Appellate Tribunal, Madras “C” Bench, dated 20.09.024 in ITA No.95/Chny/2024. ______________ Page 1 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/10/2025 01:28:46 pm ) T.C.A.No.186 of 2025 For Appellant: Mr.T.Ravikumar JUDGMENT (Delivered by the Hon'ble Chief Justice) Heard on admission. 2. The first question of law, as proposed by the Revenue, is with regard to the correctness of the view taken by the learned Tribunal in rejecting the application seeking condonation of delay in filing appeal. 3. The Tribunal has considered the cause shown by the Revenue and has arrived at a conclusion on fact that no sufficient cause was shown. Even after excluding the period from 15.3.2020 to 28.2.2022 (due to Covid-19 pandemic), the appeal was barred by 503 days, as it was filed on 12.1.2024. 4. As no sufficient cause has been shown for the delay, the proposed first question of law does not survive. Consequently, ______________ Page 2 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/10/2025 01:28:46 pm ) T.C.A.No.186 of 2025 there is no need to consider the second proposed question of law. 5. Appeal is dismissed. There shall be no order as to costs. (MANINDRA MOHAN SHRIVASTAVA, CJ) (G.ARUL MURUGAN,J)

25.09.2025 Index : Yes/No Neutral Citation : Yes/No bbr To: 1. The Assistant Registrar Income Tax Appellate Tribunal Chennai Benches, Chennai. 2. The Commissioner of Income Tax (Appeals)-6, Chennai. 3. The Principal Commissioner of Income Tax, Chennai-600 034. 4. The Assistant Commissioner of Income Tax, Corporation Circle 2(1), Chennai. ______________ Page 3 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/10/2025 01:28:46 pm ) T.C.A.No.186 of 2025 THE HON'BLE CHIEF JUSTICE AND G.ARUL MURUGAN,J. bbr

T.C.A.No.186 of 2025

25.09.2025 ______________ Page 4 of 4 https://www.mhc.tn.gov.in/judis ( Uploaded on: 03/10/2025 01:28:46 pm )

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