BHIKHABHAI SOMABHAI PATEL,SABARKANTHA vs. THE ITO, WARD-1,, HIMATNAGAR

ITA 2597/AHD/2025Status: DisposedITAT Ahmedabad18 February 2026AY 2018-199 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeals, citing the assessee's genuine cause and the potential for gross injustice if the appeals were not heard on merits. The matters were restored to the CIT(A) for fresh adjudication.

What were the facts?

The assessee, an illiterate agriculturist, failed to respond to assessment notices due to unfamiliarity with tax laws and electronic proceedings. This led to an ex-parte assessment and penalty order. The assessee's appeals to the CIT(A) were dismissed due to significant delays.

What were the issues?

Whether the delay in filing appeals by an illiterate agriculturist, due to lack of awareness of tax laws and electronic procedures, constitutes a 'sufficient cause' for condonation.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B,Section 270A,Section 57(iv)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD

Before: SHRI SANJAY GARG & SMT. ANNAPURNA GUPTA

For Appellant: Shri S. N. Divatia & Shri Samir Vora, Shri Rajkumar M Vasavda, Sr. DR
For Respondent: Shri Rajkumar M Vasavda, Sr. DR
Pronounced: 18/02/2026

PER ANNAPURNA GUPTA, AM:

Both the appeals relate to the same assessee and pertain to the same Assessment Year (A.Y.) 2018-19. While one is against the order passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (hereinafter referred to as “NFAC”) (in short “CIT(A)”), Delhi dated 14.11.2025 in quantum proceedings in assessment order passed under Section ITA Nos.2596 & 2597/Ahd/2025 [Bhikhabhai Somabhai Pate vs. ITO] A.Y. 2018-19 - 2 –

147 r.w.s. 144 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to

The order continues below.

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