SANDEEP PERNETI,NELLORE vs. ITO., WARD -1, GUDUR

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ITA 226/HYD/2025Status: DisposedITAT Hyderabad18 July 2025AY 2017-18Bench: us :9 pages

In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

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

Pronounced: 18.07.2025

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.

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