LATE VISHWAS GAJMAL SONAWANE,DHULE vs. ITO, WARD-1, DHULE, DHULE

ITA 194/PUN/2026Status: DisposedITAT Pune17 March 2026AY 2012-13Bench: DR.MANISH BORAD (Accountant Member)1 pages
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What did the Tribunal hold?

The CIT(A) dismissed the appeal filed with a delay of 971 days without condoning the delay, stating that there was no reasonable cause for the delay and thus the appeal could not be admitted. The ITAT, however, condoned the delay of 971 days, considering the peculiar facts and legal precedents.

What were the facts?

The assessee, Late Vishwas Gajmal Sonawane, did not file a return for AY 2012-13. The case was reopened under section 148, and a return was filed declaring an income of Rs. 8,50,680. Later, a rectification application under section 154 was filed, stating that capital gains on agricultural land were wrongly computed as it's not a capital asset. This was rejected by the AO.

What were the issues?

Whether the delay in filing the appeal before the CIT(A) should be condoned, and if so, whether the issue of agricultural land not being a capital asset should be adjudicated on merits.

Which sections of the Income-tax Act were involved?

Section 154,Section 139,Section 148,Section 143,Section 147,Section 2(14),Section 271(1)(c)

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

Before: DR.MANISH BORAD

For Respondent: Shri Dayanand Jawalikar
Hearing: 10.03.2026Pronounced: 17.03.2026

The captioned appeal at the instance of assessee pertaining to A.Y. 2012-13 is directed against the order dated 21.11.2025 framed by National Faceless Appeal Centre, Delhi (NFAC) arising out of Rectification Order dated 18.01.2022 passed u/s. 154 of the Income Tax Act, 1961 (in short ‘the Act’).

2.

When the case called for, none appeared on behalf of the assessee despite due service of notice of hearing. I therefore proceed to adjudicate the appeal with the assistance of ld. Departmental Representative.

3.

Brief facts of the case are that the assessee is an individual and has not filed the regular return u/s.139 of the Act and based o

The order continues below.

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