NARESH KUMAR,BALACHAUR vs. INCOME TAX OFFICER, NAWANSHAHR, NAWANSHAR

ITA 59/ASR/2025Status: DisposedITAT Amritsar11 August 2025AY 2015-16Bench: SH. UDAYAN DAS GUPTA, JUDICIAL MEMBER AND SH. BRAJESH KUMAR SINGH (Accountant Member)6 pages
AI SummaryRemanded

What did the Tribunal hold?

The ITAT found the assessee's explanation for the 143-day delay in filing the appeal to be reasonable and bona fide, thus condoning the delay. The matter was remanded back to the CIT(A) with directions to admit the appeal and decide it on its merits after providing the assessee a reasonable opportunity of being heard.

What were the facts?

The AO initiated reassessment proceedings against the assessee for A.Y. 2015-16, noting unfiled ITR and unexplained cash deposits of Rs. 79,50,450/-. An addition was made for the unexplained cash credit, which the assessee appealed to the CIT(A). The appeal was filed with a delay of 143 days, leading the CIT(A) to dismiss it *in limine* without condoning the delay.

What were the issues?

Whether the CIT(A) was justified in dismissing the appeal *in limine* due to delay without condoning it, and whether the assessee should be granted a reasonable opportunity of being heard on the merits of the addition.

Which sections of the Income-tax Act were involved?

Section 250,Section 147,Section 144,Section 144B,Section 148A(b),Section 148A(d),Section 148,Section 142(1),Section 133(6),Section 221(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: SH. UDAYAN DAS GUPTA & SH. BRAJESH KUMAR SINGH

Hearing: 20.05.2025Pronounced: 11.08.2025

Per:Brajesh Kumar Singh,AM: The instant appeal of the assessee was filed against the order of the ld. Commissioner of Income-tax (Appeals), NFAC, Delhi, (in brevity ‘the CIT (A)’ order passed u/s 250 of the Income-tax Act, 1961, dated 12.12.2024,

arising out of assessment order dated 09.03.2023 passed u/s 147 r.w.s. 144 r.w.s. 144B of the Act,for assessment year 2015-16. I.T.A. No. 59/Asr/2025 2 Assessment Year: 2015-16

2.

Brief facts of the Case: In this case, as per information received, it was found by the AO that the assessee had made cash deposits amounting

to Rs. 79,50,450/- in his two bank accounts both with Punjab National

Bank (with different TAN) during the ye

The order continues below.

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