PRANAY MAHAJAN WELFARE TRUST,AMRITSAR vs. INCOME TAX OFFICER- WARD 2(1), AMRITSAR

ITA 461/ASR/2024Status: DisposedITAT Amritsar26 September 2025AY 2023-2024Bench: the Tribunal. Only a request for adjournment has been filed on the grounds that the ld. AR is busy on professional duties. It is seen from the order sheet entries that this appeal has been adjourned earlier on three previous occasions at the instance of the ld. AR.10 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The tribunal dismissed appeals ITA Nos. 457 to 459/Asr/2024 due to the inordinate and unexplained delay in filing and non-prosecution by the assessee. For ITA Nos. 460 and 461/Asr/2024, the tribunal remanded the cases back to the first appellate authority to provide the assessee a proper opportunity of hearing on merits, directing the assessee to submit all supporting documentary evidence.

What were the facts?

The assessee, Pranay Mahajan Welfare Trust, filed multiple appeals for various assessment years. For ITA Nos. 457 to 459/Asr/2024, there were significant delays (ranging from 1284 to 2392 days) in filing appeals before the first appellate authority, and the assessee failed to appear or provide explanations for the delay. For ITA Nos. 460 and 461/Asr/2024, the issue concerned the taxation of the trust (assessed as an AOP) at the Maximum Marginal Rate (MMR) by the CPC, instead of applying slab rates, and the assessee again failed to respond to notices or provide evidence regarding its status as a private trust.

What were the issues?

Whether inordinate delays in filing appeals before the first appellate authority should be condoned; and whether a private trust, assessed as an AOP, should be taxed at the Maximum Marginal Rate (MMR) or slab rates.

Which sections of the Income-tax Act were involved?

Section 250,Section 143(1),Section 2(31),Section 154(1),Section 2(29),Section 143(1)(b),Section 143(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR

Before: DR. M. L. MEENA & SH. UDAYAN DASGUPTA

Hearing: 24.09.2025

Per Udayan Dasgupta, J.M.:

I.T.A. No. 457/Asr/2024 for A.Y. 2014-15:

This appeal is filed by the assessee against the order of the ld. Addl./JCIT(A)-4, Kolkata dated 19.06.2024 passed u/s 250 of the Income Tax Act, 1961 which has emanated from the order of the CPC, Bengaluru passed u/s 143(1) of the Act, 1961

dated 11.10.2016. 2 I.T.A. Nos. 457 to 461/Asr/2024 Assessment Years: 2014-15 & Ors.

2.

There was no appearance by the assessee or his ld. AR on the date of hearing

before the Tribunal. Only a request for adjournment has been filed on the grounds that the ld. AR is busy on prof

The order continues below.

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