Facts
The assessee-appellant filed an appeal against the order of the CIT(A) which dismissed their appeal. The appeal was filed 339 days after the prescribed limitation period. The assessee claimed ignorance of the order and stated they came to know about it on 18.07.2025. The Revenue contended that notices were issued to the assessee who remained non-compliant.
Held
The Tribunal condoned the delay in filing the appeal, considering the gravity of the issues involved which were not adjudicated on merits by the CIT(A). The appeal was restored to the file of the CIT(A) for fresh decision after providing a reasonable opportunity of being heard to the assessee.
Key Issues
Whether the delay in filing the appeal should be condoned, and if the matter should be remanded to the CIT(A) for fresh adjudication on merits, considering the assessee's plea of non-receipt of notices and non-adjudication on grounds.
Sections Cited
143(2), 142(1), 40(a)(ia), 270A, 80P, 56, 194H, 201(1A), 206C(7)
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Income Tax Appellate Tribunal, JAIPUR BENCHES,”B-Bench” JAIPUR
Before: SHRI GAGAN GOYAL, AM & SHRI NARINDER KUMAR, JM
Result
In view of the above discussion, this appeal is disposed of, for statistical purposes and the matter is restored to the files of Learned CIT(A) for decision afresh, after providing reasonable opportunity of being heard to the assessee.
Jambo Credit and Thrift Co-operative Society Ltd. Jaipur. Receipt in proof of deposit of costs to be produced by the appellant before Learned CIT(A) before commencement of proceedings on remand. File be consigned to the record room after the needful is done by the office. Order pronounced in the open court on 12/11/2025.