SUSMITA SUDHAKAR UKARDE,CHIPLUN vs. INCOME-TAX OFFICER, WARD , RATNAGIRI

ITA 3118/PUN/2025Status: DisposedITAT Pune17 March 2026AY 2016-17Bench: DR.MANISH BORAD (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal before the CIT(A) by considering the assessee's reasons as a 'reasonable cause' and relying on Apex Court judgments. The Tribunal also noted that the CIT(A) had not decided the issues on merits.

What were the facts?

The assessee's appeal against an assessment order, which was a best judgment assessment under Section 147 r.w.s.144 r.w.s.144B of the Income Tax Act, 1961, was dismissed by the CIT(A) for being barred by limitation. The assessee claimed inability to appear before the Assessing Officer due to being in a rural area and lack of technological awareness.

What were the issues?

Whether the delay in filing the appeal before the CIT(A) was to be condoned, and whether the matter should be remitted to the AO for de novo adjudication on merits.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B

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Income Tax Appellate Tribunal, PUNE BENCHES “SMC”, PUNE

Before: DR.MANISH BORAD

For Appellant: Shri Anup Shaha
For Respondent: Shri Dayanand Jawalikar
Hearing: 12.03.2026Pronounced: 17.03.2026

The captioned appeal at the instance of assessee pertaining to A.Y. 2016-17 is directed against the order dated 01.12.2025 framed by National Faceless Appeal Centre, Delhi (NFAC) arising out of Assessment Order dated 21.03.2022 passed u/s. 147 r.w.s.144 r.w.s.144B of the Income Tax Act, 1961 (in short ‘the Act’).

2.

At the outset, ld. Counsel for the assessee submitted that ld.CIT(A) has dismissed the appeal being barred by limitation and also assessee could not appear before the ld. Assessing Officer resulting into Best Judgment assessment. Only prayer is made to afford one more opportunity to go before ld.Juri ictional Assessing Officer and ld. DR supported the order of

The order continues below.

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