P.P. FINANCIERS,DINDIGUL vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

ITA 202/CHNY/2025Status: DisposedITAT Chennai09 February 2026AY 2012-13141 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeals. The Tribunal noted that the Revenue did not raise serious objections to the condonation. It referred to the guiding principles enunciated by the Hon'ble Supreme Court in Collector, Land Acquisition v. MST Katiji, which advocate for a rational, common-sense, and pragmatic approach to condoning delays, prioritizing substantial justice over technical considerations. The Court emphasized that there is no presumption of deliberate delay or culpable negligence, and a litigant does not benefit from delaying. The Tribunal found that the assessees' explanations for the delay, including awaiting other appellate orders and bank account freezes, were reasonable and did not indicate mala fide intent. Therefore, in the interest of substantial justice, the delay was condoned, allowing the appeals to be heard on merits.

What were the facts?

This batch of 61 appeals involves 11 assessees from the P. Palanisamy Group, with 4 appeals filed by the Revenue and 57 by the assessees. The appeals challenge orders passed by the Commissioner of Income Tax (Appeals)-20, Chennai, dated July 31, 2024 (or August 5, 2024 for PP Enterprises, Oddanchatram). These orders stemmed from assessment orders issued by the Assistant Commissioner of Income Tax, Central Circle–3, Coimbatore. The assessments were made under Section 153A read with Section 143(3) or 144, and Section 153C read with Section 143(3) or 144 of the Income-tax Act, 1961. The assessment years under review span from 2010-11 to 2018-19. Several assessees filed their appeals with a delay of 61 to 92 days, attributing it to awaiting other appellate orders and bank account freezes. The Revenue did not strongly object to the condonation of delay.

What were the issues?

1. Whether the Tribunal should condone the delay in filing appeals by certain assessees, considering the principles laid down in Collector, Land Acquisition v. MST Katiji [(1987) 167 ITR 471 (SC)]? Assessee's Contention: The assessees sought condonation of delay, explaining it was due to awaiting receipt of remaining appellate orders for collective filing and due to bank account freezes necessitating arrangements for appeal fees. They relied on the principles from Collector, Land Acquisition v. MST Katiji, emphasizing substantial justice over technicalities and the absence of deliberate delay. Revenue's Contention: The Revenue did not raise serious objections to the prayer for condonation of delay.

Which sections of the Income-tax Act were involved?

Section 153A,Section 143(3),Section 144,Section 153C

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(25)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

आयकर अपीलीय अधिकरण, ’सी’ यायपीठ, चेनई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH: CHENNAI

,

BEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRI S.R.RAGHUNATHA, ACCOUNTANT MEMBER

आयकर अपील सं./ITA Nos.1119, 1120 & 1121/Chny/2025 नधारण वष/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./ITA Nos.209 to 213 & 214/Chny/2025 नधारण वष/Assessment Years: 2010-11 to 2014-15 & 2016-17

Mr. P. Palanisamy, 390, P.P. Nilayam, 9 th Main I Cross, HAL II Stage, Indira Nagar, Bengaluru-560 038. v. The ACIT, Central Circle-3, Coimbatore. [PAN:ADSPP 9150 F] (अपीलाथ/Appellant) (यथ/Respondent)

आयकर अपील सं./ITA Nos.219, 220, 221 & 222/Chny/2025 नधारण वष/Assessment Years: 2015-16, 2010-11, 2017-18 & 2018-19 & आयकर अपील सं./ITA Nos.200, 201 to 208/Chny/2025 नधारण वष/Assessment Years: 2016-17, 2011-12 to 2018-19 & आयकर अपील सं./ITA Nos.3388 to 3392/Chny/2024 िनधारण वष/Assessment Years: 2014-15 to 2018-19

M/s. P.P. Financers, 24, Radha Avenue, 3 rd Street, Valsaravakkam, Chennai-600 087. v. The ACIT, Central Circle-3, Coimbatore. [PAN: AAHFP 0288 L] (अपीलाथ/Appellant) (यथ/Respondent)

आयकर अपील सं./ITA Nos.215 to 218 & 223/Chny/2025 िनधारण वष/Assessment Years: 2015-16 to

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 153A

All 18,957 judgments and leading authorities on Section 153A →

Recent GST High Court judgments

Search GST case law →