KASIREDDY SASIKALAMMA,NELLORE vs. ITO., WARD -1, GUDUR

Facts

The assessee's income for AY 2017-18 was reassessed under Section 147 of the Income Tax Act, 1961, after it was found that she had advanced an unsecured cash loan but had not filed her return. The Assessing Officer made additions for unexplained money, investment, cash credit, drawings, and unsubstantiated agricultural income. The CIT(A) partly allowed the appeal, deleting additions for cash in hand and drawings but confirming others.

Held

The Income Tax Appellate Tribunal (ITAT) dismissed the assessee's appeal as barred by limitation. The assessee sought condonation for a 350-day delay in filing the appeal, claiming her previous CA left without handing over papers, but the ITAT found the submitted affidavit to be a 'bogus document' as it was notarized on a date different from when the appeal was purportedly filed, indicating a lack of 'clean hands'.

Key Issues

Whether there was sufficient and genuine cause for condoning the 350-day delay in filing the appeal before the ITAT, considering the authenticity and dates mentioned in the affidavit submitted for condonation of delay.