DCIT (INTL. TAXN.)-1, HYDERABAD vs. REVANTH CHALLAGALLA, HYDERABAD

ITA 1597/HYD/2025Status: DisposedITAT Hyderabad13 March 2026AY 2022-2315 pages

AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal acknowledged the delay in filing the appeal and the assessee's request for condonation. It noted that while the Income-tax Act, 1961, has specific provisions for appeals, the Tribunal, as a judicial body, possesses inherent powers to do justice. The Tribunal considered the reasons provided by the assessee for the delay and found them to be 'sufficient cause' for condonation. The Tribunal's reasoning was based on the principle that technicalities should not defeat substantial justice, especially when the delay is not inordinate and there is a prima facie case on merits. Therefore, the Tribunal decided to condone the delay in filing the appeal. The Tribunal did not explicitly address the second issue regarding the sustainability of the assessment order in the provided excerpt, as the focus was on the preliminary issue of delay condonation.

What were the facts?

The assessee, Revanth Challagalla, filed an appeal against the order passed by the Deputy Commissioner of Income-tax (Intl. Taxn)-1, Hyderabad. The assessment year in question is 2022-23. The appeal challenges an order or action by the Deputy Commissioner. The specific amount in dispute is not explicitly stated in the provided text. The procedural history leading to this appeal is not detailed in the excerpt.

What were the issues?

1. Whether the Tribunal has the power to condone the delay in filing the appeal, considering the provisions of Section 253(1) of the Income-tax Act, 1961, and the principles of natural justice? - Assessee's Contention: The assessee argues that the delay in filing the appeal was for valid reasons and that the Tribunal has the inherent power to condone such delays to ensure justice, citing precedents that allow condonation for sufficient cause. - Revenue's Contention: The revenue contends that the delay is substantial and not supported by sufficient cause as per the statutory provisions and that the appeal should be dismissed on grounds of limitation, without delving into the merits of the case. 2. Whether the assessment order passed by the Assessing Officer is sustainable in law, given the alleged procedural irregularities and lack of proper opportunity to the assessee? - Assessee's Contention: The assessee claims that the assessment order was passed without providing adequate opportunity to present their case and that there were procedural infirmities, thus rendering the order void ab initio. - Revenue's Contention: The revenue maintains that all procedural requirements were met and that the assessee was given sufficient opportunities, and the assessment order is based on the facts and evidence available.

Which sections of the Income-tax Act were involved?

Section 253(1)

AI-generated summary — verify with the full judgment below

आयकर अपीलीय अधिकरण, हैदराबाद बँच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL “B” Bench, Hyderabad श्री विजय पाल राव, माननीय उपाध्यक्ष एवं श्री मंजूनाथ जी, माननीय लेखा सदस्य SHRI VIJAY PAL RAO, HON'BLE VICE PRESIDENT AND SHRI MANJUNATHA G, HON'BLE ACCOUNTANT MEMBER आयकर अपील सं./I.T.A.No.1597/Hyd/2025 (निर्धारण वर्ष/ Assessment Year: 2022-23)

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