GRAY MATTERS CAPITAL INC,UNITED STATES OF AMERICA vs. DEPUTY DIRECTOR OF INCOME TAX, BENGALURU

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ITA 7918/DEL/2025Status: DisposedITAT Delhi24 December 2025AY 2022-23Bench: Sh. Satbeer Singh Godara (Judicial Member)2 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that technicalities must give way to substantial justice. The appeal was restored to the CIT(A) for a fresh adjudication, allowing the assessee three opportunities to plead and prove their case.

What were the facts?

The assessee's appeal arose from an order refusing to condone a delay of 475 days in filing a lower appeal against the CPC's processing order. The delay was attributed to circumstances beyond the assessee's control.

What were the issues?

Whether the delay in filing the appeal was sufficiently explained and whether the CIT(A) erred in refusing to condone it, prioritizing technicalities over substantial justice.

Which sections of the Income-tax Act were involved?

Section 143(1)

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Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’, NEW DELHI

Before: Sh. Satbeer Singh Godara

Hearing: 24.12.2025Pronounced: 24.12.2025

ORDER This assessee’s appeal for Assessment Year 2022-23 arises against the Addl./JCIT(A)-2, Hyderabad’s DIN & order No.ITBA/APL/S/250/2025-26/1081218586(1) dated 26.09.2025, in proceedings u/s 143(1) of the Income Tax Act, 1961 (in short “the Act”).

2.

Heard both the parties at length. Case file perused.

3.

It emerges during the course of hearing with the able assistance coming from both the sides that the learned CIT(A) has refused to condone delay of 475 days in filing of the assessee’s lower appeal instituted on 17.10.2024 against the CPC’s impugned section 143(1) “processing” dated 31.05.2023 thereby holding that the same had not been explained in light of the justifiable reasons.

1.

Gray Matters Capital Inc. 4. Faced with this situation, learned departmental representative could hardly dispute that the assessee had indeed explained the above delay before the CIT(A) explaining all the reasons on account of circumstances beyond it’s control.

5.

That being the case, I hereby quote Collector, Land & Acquisition Vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC), settling the issue long back that all such technical aspects must make way for the cause of substantial justice and restore the assessee’s instant appeal back to the CIT(A) for his afresh appropriate adjudication within three effective opportunities subject to a rider that the assessee shall plead and prove the case at his own risk and responsibility, in consequential proceedings. Ordered accordingly.

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