SANDEEP PERNETI,NELLORE vs. ITO., WARD -1, GUDUR
In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal observed a serious discrepancy in the affidavit for delay condonation, noting it was notarized on 05.02.2025 but referred to the appeal being filed on 13.02.2025. Finding the affidavit to be a 'bogus document' and that the assessee did not approach with clean hands, the Tribunal refused to condone the delay. Consequently, the appeal was dismissed as barred by limitation.
What were the facts?
The assessee's assessment was reopened under Section 147 for Assessment Year 2017-18, treating an unsecured cash loan of Rs. 12 lacs as unexplained money under Section 69A due to non-filing of return and lack of source explanation. The CIT(A) dismissed the assessee's appeal due to non-participation and lack of evidence. The assessee then filed an appeal before the ITAT, which was delayed by 66 days, and sought condonation of delay with an affidavit.
What were the issues?
Whether the delay in filing the appeal should be condoned based on an affidavit containing discrepancies, and whether the assessee demonstrated sufficient cause for the delay.
Which sections of the Income-tax Act were involved?
Section 147,Section 144B,Section 69A,Section 148,Section 142(1)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, Hyderabad ‘ SM-A ‘ Bench, Hyderabad
आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:-
1. 1. निर्धाररती/The Assessee : Sandeep Perneti, 13-104, Upstairs Sivasakti Showroom, CVC Park, Gudur – 524101, Nellore. 2. रधजस्व/ The Revenue : Income Tax Officer, Ward -1, Gudur.
More judgments on Section 147
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Tarunaben Maganlal Bhut, Navagam vs ITO Ward 2(2)(1), RajkotITA 673/RJT/2026[2024-25]Status: Disposed21 Oct 2026AY 2024-25
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
Recent GST High Court judgments
Search GST case law →- Mahaveer Ispat Traders vs. Principal Commissioner Dgst Delhi Department Of Trade And Taxes Gnctd & Anr.Delhi · 28 Oct 2026
- Modern Engineers And Contractors vs. The Deputy Assistant Commissioner (St)Andhra Pradesh · 28 Oct 2026
- K Madhusudan Reddy vs. The State Of Andhra PradeshAndhra Pradesh · 28 Oct 2026
- Sandeep Ranjan Rout vs. The Commissioner Of CT And GST, Odisha, KatakOrissa · 28 Oct 2026
- Gagan Bihari Rout@Gagan Rout vs. State Of OdishaOrissa · 28 Oct 2026