PRAJYOTH KUMAR ADI,HYDERABAD vs. ITO, WARD-4(1), HYDERABAD

ITA 2078/HYD/2025Status: DisposedITAT Hyderabad20 March 2026AY 2020-219 pages
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What did the Tribunal hold?

The Tribunal condoned the delay of 28 days in filing the appeal before it, finding substance in the assessee's claim that notices from the CIT(A)'s office were not sent to the provided email address (padi.kumar@gmail.com) but to other email IDs. The Tribunal held that the failure of the CIT(A)'s office to forward the appellate order to the specified email address supported the assessee's contention that the delay was not attributable to his fault. Furthermore, the Tribunal found that the CIT(A)'s office had failed to carry out a valid service of notice intimating the fixation of the appeal, precluding the assessee from presenting his case. In the interest of justice, the Tribunal set aside the matter to the file of the CIT(A) with a direction to readjudicate the appeal afresh after validly putting the assessee to notice and affording a reasonable opportunity of being heard. The penalty appeal was also set aside to be disposed of after the quantum appeal. The appeals were allowed for statistical purposes.

What were the facts?

The assessee, Prajyoth Kumar Adi, filed appeals before the ITAT Hyderabad Bench against orders of the CIT(A) concerning Assessment Year 2020-21. The original assessment order was passed by the AO under section 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961, on 17/12/2024, and a penalty order under section 270A was passed on 05/06/2025. The AO initiated reassessment proceedings based on information about substantial financial transactions, including sale of immovable property for Rs.1,08,40,000/- and receipt of interest income of Rs.1,44,752/-, which the assessee had not offered to tax. The assessee failed to comply with notices issued by the AO. The CIT(A) dismissed the assessee's appeals on grounds of delay, holding that the appeals were filed 118 days late and there was no sufficient cause for the delay. The assessee contended that notices from the CIT(A)'s office were sent to incorrect email addresses.

What were the issues?

1. Whether the CIT(A) erred in dismissing the appeal on the ground of delay in filing, and whether there was indeed a delay, considering the facts and circumstances? 2. Whether the CIT(A) erred in dismissing the appeal without putting the appellant on notice about the delay? Assessee's Contention: The assessee argued that there was no delay in filing the appeal before the CIT(A). The delay of 28 days (as per the assessee's submission to the ITAT) occurred because notices from the CIT(A)'s office were sent to email addresses other than the one provided by the assessee in Form-35 (padi.kumar@gmail.com). The assessee only became aware of the dismissal of his appeal on 19/11/2025 when his Chartered Accountant logged into the portal. The assessee relied on an affidavit and a notice from the AO regarding outstanding demand. Revenue's Contention: The Revenue, through the Ld. Sr-DR, did not seriously object to the condonation of the delay in filing the appeal before the ITAT.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B,Section 270A,Section 148A,Section 148,Section 142(1),Section 249(3)

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Income Tax Appellate Tribunal, Hyderabad B Bench, Hyderabad

PER RAVISH SOOD, JM: The captioned appeals filed by the assessee are directed against the orders passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (for short, “CIT(A)”), dated 07/08/2025 and 30/09/2025, which in turn arise from the respective orders passed by the Assessing Officer (“AO”) under section 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961 (for short, “the Act

The order continues below.

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