MAYURI ELECTRONICS PRIVATE LIMITED,NAMAKKAL vs. DCIT CIRCLE-1, ERODE, ERODE

At the threshold, we observe that there is a delay of 851 days in the filing of the present appeal by the assessee. The assessee has furnished an affidavit explaining that the assessee has no knowledge of faceless proceedings and former Chartered Accountant also failed to effectively track and communicate the notices for timely compliance and the assessee became aware of the impugned order passed by the ld.CIT(A) only after receiving of notice u/s.221 of the Act dated 15.12.2025 regarding outstanding demand for A.Y.2014-15 and immediately filed the appeal on 29.12.2025 before the Hon’ble Tribunal. The ld.AR for the assessee prayed for condoning the delay in filing the appeal before this Tribunal by referring to the Affidavit and prayed for one more opportunity to the assessee.

Per contra, the ld.DR submitted that the assessee has filed this appeal with an exorbitant delay without having any sufficient reason before the ld.CIT(A) and hence the ld.CIT(A) has rightly dismissed this appeal without admitting the same. Therefore, the ld.DR submitted that the delay cannot be condoned and prayed for dismissing the appeal.

We have heard the case, perused the materials on record, and gone through orders of the authorities below. Upon perusal of the affidavit and after affording due opportunity of hearing from both parties, there is an admitted delay of 851 days in filing the present appeal before the Tribunal against the order passed u/s.250 of the Act dated 26.06.2023. The assessee has furnished an affidavit explaining that the assessee has less knowledge of new faceless proceedings and former Chartered Accountant also failed to effectively track and communicate the notices for timely compliance and the assessee became aware of the impugned order passed by the ld.CIT(A) only after receiving of notice u/s.221 of the Act dated 15.12.2025 regarding outstanding demand for A.Y.2014-15. 7. The delay involved in the present case is substantial and inordinate, being 851 days. The law is well settled that while the expression “sufficient cause” should be construed liberally, the party seeking condonation must demonstrate bona fide reasons explaining the entire period of delay. In the present case, the explanation offered by the assessee is general in nature, namely lack of knowledge of faceless proceedings and dependence on Chartered Accountants. No specific dates, circumstances, or material evidence have been furnished to explain the delay for each period. Mere assertion of ignorance of law cannot constitute sufficient cause.

The conduct of the assessee shows that after filing the appeal, no participation in the appeal proceedings before the ld.CIT(A). The plea that he became aware of the order only recently is therefore not acceptable. The affidavit lacks credibility and does not inspire confidence.

It is settled law that inordinate delay cannot be condoned on vague and general grounds, particularly when the conduct of the party shows conscious inaction and acquiescence. In view of the above facts and circumstances, we are of the considered opinion that the assessee has failed to establish sufficient cause for condoning the delay of 851 days in filing the appeal before the Tribunal. Accordingly, the condonation petition is rejected. Since the delay is not condoned, the appeal filed by the assessee is dismissed in limine as barred by limitation.

In the result, the appeal filed by the assessee is dismissed.

अपीलाथȸ/Appellant 2. Ĥ×यथȸ/Respondent 3.आयकर आयुÈत/CIT– Chennai/Coimbatore/Madurai/Salem 4. ͪवभागीय ĤǓतǓनͬध/DR 5. गाड[ फाईल/GF