SRI TIRUMALA ESTATES AND FARMLANDS,VISAKHAPATNAM vs. ACIT, CENTRAL CIRCLE-1, VISAKHAPATNAM

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ITA 552/VIZ/2025Status: DisposedITAT Visakhapatnam14 November 2025AY 2017-18Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)20 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee's reasons for the significant delay in filing appeals were not bona fide and demonstrated negligence and a casual approach. The Tribunal emphasized that the law of limitation must be applied with rigor and liberal approaches are not extended to gross negligence.

What were the facts?

The assessee, a partnership firm in real estate, failed to file its income tax return for AY 2017-18. A survey revealed discrepancies in sale prices and expenses, leading to an ex-parte assessment order. The assessee appealed the assessment and penalty orders belatedly, citing ignorance of online procedures and issues with their tax practitioner.

What were the issues?

The primary issue was whether the delay in filing appeals before the CIT(A) could be condoned based on the reasons provided by the assessee. The Tribunal also considered the assessee's conduct throughout the proceedings.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 270A,Section 133A,Section 148,Section 142(1),Section 40(a)(ia),Section 249,Section 139

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Income Tax Appellate Tribunal, Visakhapatnam Bench

आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:-

1. 1. निर्धाररती/The Assessee : Shri Tirumala Estates and Farmlands, D.No.9-39-1/2, Flat No.102, Sai Sampath Enclave, Pithapuram Colony, Maddilapalem, Visakhapatnam. 2. रधजस्व/ The Revenue : The Assistant Commissioner of Income Tax, Central Circle – 1, Visakhapatnam.

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