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Facts
The assessee, a cooperative credit society, is appealing against orders from the CIT(A)/NFAC that dismissed its appeals due to delays in filing. The appeals concern quantum additions and penalties for Assessment Years 2018-19 and 2020-21.
Held
The Tribunal condoned the delay in filing the appeals before the CIT(A)/NFAC, noting that a reasonable cause prevented the assessee and the delay was not intentional. The matters were restored to the file of the CIT(A)/NFAC for adjudication on merits.
Key Issues
Whether the delay in filing appeals before the CIT(A)/NFAC should be condoned, and whether the matters should be remanded for adjudication on merits.
Sections Cited
80P, 144, 270A, 271AAC(1), 250(6)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE
Before: SHRI MANISH BORAD & SHRI VINAY BHAMORE
PER BENCH : By way of above captioned appeals, the assessee’s appeal in ITA Nos.177 – 178/PUN/2025 for A.Ys. 2018-19 and 2020-21 are directed against the order of Ld. CIT(A)/NFAC dated 30.07.2024 and for remaining assessee’s appeals relating to penalty levied u/s 270A for A.Ys. 2018-19 and 2020-21 and u/s 271AAC(1) for A.Y. 2020-21 are directed against the order of Ld. CIT(A)/NFAC dated 13.01.2025 and 07.01.2025 respectively.
Since all the above captioned appeals relates to the same assessee of which ITA Nos.177 – 178/PUN/2025 are the quantum appeals and remaining three are penalty appeals, all the appeals were heard together and are being disposed of by this consolidated order for the sake of convenience and brevity.
At the outset, Ld. Counsel for the assessee referring to the following written submissions has mainly contended that Ld. CIT(A)/NFAC has either not condoned the delay or has not passed the orders on merits of the case and, therefore, prayer is made for restoring the issues raised in all the instant appeals relating to the quantum/penalty to the file of Ld. CIT(A)/NFAC for necessary adjudication :- “SHREE NARSINHA NAGARI SAHAKARI PATSANSTHA NARSINH BUILDING, A/P RANJANI, TAL. AMBEGAON, AMBEGAON, DIST. PUNE - 410504, Maharashtra June 25, 2025 The