AUDREY BERNICE ROY,VISAKHAPATNAM vs INCOME TAX OFFICER, VISAKHAPATNAM

Income Tax Appellate Tribunal, VISAKHAPATNAM “SMC” BENCH, VISAKHAPATNAM

Before: SHRI RAVISH SOOD, HON’BLE

For Appellant: Shri M. Muralidhar, CA

For Respondent: Shri D. Hema Bhupal, Sr.DR

Pronounced: 18.02.2026

आदेश /O R D E R

PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order passed by the Additional/Joint Commissioner of Income Tax (Appeals)-7, Delhi, dated 08.07.2025, which in turn arises from the intimation issued by the Assessing Officer/Centralized Processing Center (for short, “A.O/CPC”) under

I.T.A.No.494/VIZ/2025 Audrey Bernice Roy

section 143(1) of the Income-Tax Act, 1961 (for short, “the Act”), dated 27.01.2020 for the Assessment Year 2017-18. The assessee has assailed the impugned order on the following grounds of appeal:

“1. The order of Ld. AO (CPC) as well as Ld CIT(A) are contrary to the facts and also the provisions / law applicable to the facts of the case. 2. DOUBLE TAXATION NOT PERMISSIBLE IN INCOME TAX ACT: Ld AO-CPC has erred in adjusting Rs. 12,05,509/- as "Income other sources" being a double taxation as Centralized Processing Centre is not Authorized to do adjustments u/s 143(1), when there is no claim at all, this being not a Salary as per reply of the assessee as taxable u/s 44ADA to proposed adjustments u/s 143(1)(a). Article 265 of the Constitution of India, It is settled law that "No tax shall be levied or collected except by authority of law". 3. CENTRALIZED PROCESSING CENTRE NOT AUTHORIZED TO DO ADJUSTMENTS WHEN THERE IS NO CLAIM AT ALL : 3.1 The Ld AO-CPC is completely erred in carrying out the adjustments beyond the scope of authority and hence not as per the provisions of sec 143(1). The assessee has not made any incorrect claim except as per the provisions of the act. It does not fall the definition of Incorrect claim as defined under sec 143(1)(i) to (iii) too. 3.2 CPC PROCESSING - ADDITIONS CANNOT GO BEYOND INCOME APPEARING IN FORM 26AS NOT DECLARED IN ITR: The Ld AO-CPC has erred in making additions and gone beyond the income displayed in form 26AS. The same was held in the following case in a similar case as shown below and it was held "The AO is directed to take necessary rectificatory action to tax the gross receipts u/s 44ADA alone." It was held in Arthur Bernard Sebastine Pais vs DCIT-CPC, (BANG-Trib.): (2019) 74 TLC 241, on 16.10.2019

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3.3 This is neither as per CDT vide Notification No. 3/2012, dt. 4-1- 2012 nor as per CBDT vide Notification No. 2/2012, dated 4-1-2012 has specified the Centralised Processing of Returns Scheme, 2011. 4. NON-CONSIDERATION OF PLEA OF ASSESEE AND ORDER PASSED WITHOUT APPLICATION OF MIND: Ld AO-CPC has not computed u/s 44ADA neither u/s 194J as per Form 26AS nor as per the assessee's reply, the order was passed without considering the reply and had passed an arbitrarily without application of mind and hence Intimation cum assessment order is null & void. 5. ADDITIONS OF TWO INCOMES NOT PORTRAYED IN THE INTIMATION U/S 143(1)(a): 5.1 ADDITIONS BEYOND SCOPE OF PROVISIONS OF SEC 143(1)(a): Ld AO has erred in not depicting that any income other than the income of Rs. 14,16,609/- is proposed to be taxed in the notice issued u/s 143(1)(a), without providing an opportunity in retaining the salary without rectification & making it zero being Professional income and taxing again an amount to Rs. 14,16,609/- as other sources (though form 26AS shows the same u/s 194J) and the reply of the assessee was not taken into consideration as sec 44ADA though shown in sec 143(1)(a) in the proposed adjustment. Therefore, the same is beyond the scope of Provision of Sec 143(1). 5.2 ADDITIONS MADE ON IRRELEVANT MATERIAL, NON- EXISTENT FACT OR ON PRESUMPTION, ON CONJECTURES, SURMISES NOT SUSTAINABLE: The Ld AO-CPC is not justified in processing the return with a mistake classifiable u/s 154, which is visible clearly from the record with a naked eye and should have issued final SCN before doing so. Hence the impugned intimation issued was arbitrary and erroneous. While making addition on that issue, it may be possible that the AO-PC was influenced by some irrelevant or nonexistent fact. The same was held by Hon'ble Apex Court in Dhirajlal Girdharilal v CIT [1954] 26 ITR 736 (SC). 5.3 ADDITION PREMISED ON SUSPICION OR SURMISE: The Ld AO-CPC has failed to appreciate that surmises, conjecture and suspicion could not be a basis much less a valid basis in processing the income chargeable u/s 4. Therefore, the said action is not sustainable, as was held in

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- ESTHURI ASWANTHIAH v. CIT 1968 AIR 36 1967 SCR (3) 681 dtd 18/04/1967 - Shri Raj Kumar (M/S Radhika Sales Corp) vs Income Tax Officer Ward- 3(3), Amritsar on 11 April, 2023 (I.T.A. No.195/Asr/2022). 6. NON-SPEAKING ORDER OF AO-PC BEING INCOME ASSUMED WRONGLY WITHOUT ANY BREAK UP: The Ld AO is not justified in not providing any reason treating the 26AS as extra income & taxing Salary again makes it a taxing twice since reply of the assessee was 44ADA which ought have been taxed at 50% u/s 44ADA on Rs. 13,55,009/- (Form 26AS shows lower amount of Rs. 13,19,139/-), where as Ld AO has made addition of Rs. 14,16,609/- at 100% too apart from salary of Rs. 12,05,509/-. The total receipts as perform 26AS comes to Rs. 14,28,837/- when compared to Income of Rs. 14,16,609/- shown in intimation u/s 143(1)(a) arbitrarily, hence void ab-initio. The same observations were made by Hon'ble Supreme Court Union Public Service Commission v. Bibhu Prasad Sarangi and Ors., [2021] 4 SCC 516. 7. HIGH PITCHED ASSESSMENT PASSED ON MERE SUSPICION: The Ld AO-CPC has erred in not applying his mind and passed the impugned erroneous order/intimation u/s 143(1) summarily on suspicion & in arbitrary manner. Therefore, the assessment fails and void ab-initio. 8. Principles of Natural Justice violated: 8.1 Ld AO-CPC has erred in not following the procedure as prescribed u/s 282(1) read with rule 127(1), where all the notices/Intimations were uploaded in the e-portal, and just presumed that the same was served properly to assessee. It was clearly held in the following case law: [Court Rules in Favour of Fair Hearing] "Placing notice on e-portal is not service; Communication cannot be 'presumed'." MUNJAL BCU CENTRE OF INNOVATION AND ENTREPRENEURSHIP v. CIT [04.03.2024 (P & H - HC), vide (2024) 160 taxmann.com 629 8.2 Otherwise defense mechanism fails rather otiose, even when the situation is looked at from time barred aspect too. Since this is also not a mistake of assessee, since Intimation u/s 143(1).

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The same is not downloadable though hanging in the e-portal. However, the assessee is liable to pay only Rs. 86,681 only and not Rs. 6,00,000/-as per the demand notice/Asst order. (Enclosed actual Computation sheet u/s 44ADA as per the act before the hon'ble bench). 9. Burden of Proof is on the part of revenue and not on the assessee, since intimation u/s 143(1) which is also deemed to be demand as per the provisions of the sec 143(1) also fails. There is no alternate remedy under the act to bring the issue to the department or higher authority except filing appeal to before the honourable bench as it goes to root of the matter. 10. The huge interest were charged u/s 234A, B & C may be waived, since the same was arising due to impugned additions in sec 143(1)(a) according to the wrong facts & observations as per the grounds mentioned above. 11. Any other ground that may be add/delete or urged at the time of hearing or before the hearing.”

Succinctly stated, the assessee had filed her return of income for the A.Y. 2017-18 on 08.09.2017, declaring an income of Rs. 13,40,509/-. Ostensibly, the income returned by the assessee was comprised of, viz. (i) Income from House Property: Rs. 1,35,000/-; (ii) Income from Salary: Rs. 12,05,509/-; and (iii) Income from Other Sources: Rs. NIL. Thereafter the AO/CPC, Bengaluru vide an intimation issued under section 143(1) of the Act, dated 11.01.2019, determined the income of the assessee at Rs. 27,57,118/- which comprised of, viz. (i) Income from Salary: Rs.12,05,509/-; (ii) Income from House Property: Rs.1,35,000/-; and (iii) Income from Other Sources: Rs.14,16,609/-. Accordingly, the AO/CPC, Bengaluru, based on the aforesaid intimation dated 11.01.2019, raised a demand of Rs. 6,36,000/- in the hands of the assessee.

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Aggrieved, the assessee carried the matter in appeal before the CIT(A). As the appeal filed before the CIT(A) involved a delay of 1503 days, the latter declined to exercise the discretion vested with him under section 249(3) of the Act and dismissed the appeal on the ground of limitation. For the sake of clarity, I deem it apposite to cull out the observations of the CIT(A), as under: -

“2. Decision :- 2.1 As mentioned at the outset, against the assessment order u/s 143(1) of the Act dated 27.01.2020, the appellant filed an appeal vide Form No.35 dated 07.04.2024. From the date of service of the order it is seen, that there is a delay of 1503 days in filing appeal. The appeal should have been filed within 30 days i.e. by 26.02.2020 from service of Order / Notice of Demand as per Section 249(2) of the Act. In column no. 14 of Form No. 35, the appellant has admitted to the delay in filing and has given the reason for condonation of delay which is as under:-. "There is a delay 1501 days due to non availability or non communication of intimation u/s 143(1). The same is visible in the portal as if uploaded(assessed) on 11-01-2019 but assessee is unable to download from the portal and running from pillar to post to get a copy of that for filing appeal. The delays are not attributable top assessee and file this appeal immediately. Hence the delay may be condoned" 2.2 The relevant screenshot are pasted below for instant reference:-

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2.3 After considering the assessee's reasons, this office is not satisfied that there was sufficient cause for the delay in filing the appeal as there is a delay of 1503 days in filing appeal. The assessee's waiting for action on the response filed is not a valid reason for delay, as the assesse should have taken timely action to file the appeal. 2.4 There is a statutory limit prescribed for filing of appeal in the Act. The invocation of the power to condone any delay, major or minor, in observing such time limit is possible only on the satisfaction of the Addl./JCIT (Appeal) regarding the appellant having been unable to file the appeal in time due to sufficient cause The appellant cannot be entitled to automatic admission of appeal filed after the time limit. This is not a substantiated and valid argument. Ignorance of law or of proceedings under law cannot be taken as an excuse. The onus lay on the appellant to keep track of the email and proceedings in his case. Digital or e-proceedings are the norm of the day now in this modern era and proceedings in the department have been digitized and are carried out through digital medium. The act of the appellant in not filing appeal within time and not having any credible reason by way of sufficient cause for delay in filing cannot be condoned. 2.5 The statute clearly lays down the timeline for filing appeal. Any deviation from the same can be condoned only if there is presence of sufficient cause for the same as found by the adjudicating authority. The unsubstantiated reason given by the appellant for delay is not found to fall within the four corners of 'sufficient cause' for the same, thereby rendering it ineligible for condonation and admission. Thus, this brief and unsubstantiated as well as invalid reason given by the appellant for delay of 1503 days is not found to be sufficient cause for the same. 2.6 In the instant case, the issue of the merits of the additions made by the AO and the grounds of appeal raised by the appellant could be taken up only when this first stage of delay was addressed. 2.7 In the case of Ajay Dabra vs Pyare Ram dated 31 January, 2023, Hon'ble Supreme Court has held that - "What we have here is a pure civil matter. An appeal has to be filed within the stipulated period, prescribed under the law. Belated appeals

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can only be condoned, when sufficient reason is shown before the court for the delay. The appellant who seeks condonation of delay therefore must explain the delay of each day. It is true that the courts should not be pedantic in their approach while condoning the delay, and explanation of each day's delay should not be taken literally, but the fact remains that there must be a reasonable explanation for the delay. In the present case, this delay has not been explained to the satisfaction of the court....n the case of Mahant Bikram Dass Chela versus Financial Commissioner, Revenue, Punjab, Chandigarh and Others (SC) has held "Section 5 of the Limitation Act is a hard task-master and judicial interpretation has encased it within a narrow compass. A large measure of case-law has grown around Section 5, its highlights being that one ought not easily to take away a right which has accrued to a party by lapse of time and that therefore a litigant who is not vigilant about his rights must explain every day's delay..... This Court in the case of Basawaraj and Another versus Special Land Acquisition Officer (SC) while rejecting an application for condonation of delay for lack of sufficient cause has concluded in Paragraph 15 as follows: "The law on the issue can be summarized to the effect that where a case has been presented in the court beyond limitation, the applicant has to explain the court as to what was the "sufficient cause" which means an adequate and enough reason which prevented him to approach the court within limitation. In case a party is found to be negligent, or for want of bona fide on his part in the facts and circumstances of the case, or found to have not acted diligently or remained inactive, there cannot be a justified ground to condone the delay. No court could be justified in condoning such an inordinate delay by imposing any condition whatsoever. The application is to be decided only within the parameters laid down by this Court in regard to the condonation of delay. In case there was no sufficient cause to prevent a litigant to approach the court on time, condoning the delay without any justification, putting any condition whatsoever, amounts to passing an order in violation of the statutory provisions and it tantamounts to showing utter disregard to the legislature. 2.8 In view of the facts as discussed hereinabove and the judicial decisions on the matter of delay in filing appeals, this appeal is not admitted for adjudication as it is delayed and not filed within the time limit provided and no sufficient cause has been provided by the appellant for the delay. In the absence of sufficient cause for the delay, the same cannot be condoned. 3. In the result, the appeal is dismissed as not admitted.”

Aggrieved with the order of the CIT(A), the assessee has carried the matter in appeal before the Tribunal.

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I have heard the Learned authorised representatives of both parties and perused the orders of the authorities below and also the material available on record, as well as considered the judicial pronouncements that have been pressed into service by the learned authorised representative of the assessee.

Shri M. Muralidhar, CA, Learned Authorised representative (for short, “Ld. AR”) for the assessee, at the threshold of hearing of the appeal submitted that the assessee had suffered the impugned double addition in the hands of AO/CPC, Bengaluru, which had resulted in an exorbitant tax demand of Rs. 6,36,000/-. Elaborating on his contention, the Ld. AR submitted that the assessee, who is an English professor with “BC Examinations and English Services India Private Limited”, had filed her return of income for the subject year, i.e., A.Y.2017-18, wherein she had inadvertently disclosed her professional receipts under the head salary. The Ld. AR had drawn our attention to the intimation issued by the AO/CPC, Bengaluru, issued under section 143(1) of the Act dated 11.02.2012, wherein against the income returned at Rs. 13,40,509/-, the same was determined by the AO/CPC, Bangalore at Rs. 27,57,118/-.

I find that the assessee aggrieved with the order of AO/CPC, Bangalore, passed under section 143(1) dated 11.01.2019, had carried the matter in appeal before CIT(A), who declined to condone the inordinate delay of 1503 days that was involved in the appeal filed before him.

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The Ld. AR submitted that the impugned delay in filing the appeal before the CIT(A) had crept in for the reason that she could not download the intimation issued by the AO/CPC, Bengaluru, that was issued under section 143(1) of the Act, dated 11.01.2019. The Ld. AR submitted that the CIT(A) had grossly erred in law and facts in not considering the explanation of the assessee and summarily dismissing her appeal on the ground of limitation itself. The Ld. AR, in his attempt to impress that the impugned delay in filing the appeal had crept in because of failure on the part of the assessee to download the intimation from the income tax portal account, had drawn support from the assessee’s “affidavit” dated 15.04.2024 (photocopy placed on record). Also, the Ld. AR had drawn my attention to a screenshot of the intimation issued by the AO/CPC, Bengaluru, under section 143(1) of the Act, dated 23.04.2024, which revealed the error in downloading the same. Elaborating further on his contention, the Ld. AR submitted that the assessee was able to download the intimation issued by the AO/CPC under section 143(1) of the Act only as on 02.04.2024. Carrying his contention further, the Ld. AR submitted that the assessee had, thereafter, involving no further loss of time, filed the appeal before the CIT(A) on 07.04.2024, but, as the same involved a delay of 1503 days, the same was dismissed by him on the ground of limitation itself. The Ld. AR submitted that as the CIT(A) had without considering the bonafide reasons leading to the delay in filing the appeal, dismissed the same, therefore, in all fairness and interest of justice the matter be restored to his file with a direction to condone the delay

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and dispose of the appeal on merits after affording a reasonable opportunity of being heard to the assessee.

Per contra, Shri D. Hema Bhupal, Learned Senior Departmental Representative (for short, “Ld. DR”) supported the order of the CIT(A). The Ld. DR submitted that as the delay of 1503 days involved in the appeal before the CIT(A) is inordinate, therefore, he had rightly declined to exercise the discretion vested with him under section 249(3) of the Act and dismissed the appeal on the ground of limitation itself. The Ld. DR had drawn our attention to the fact that the AO/CPC, Bengaluru, had vide his communication dated 06.07.2018 pointed out to the assessee an inconsistency in his return of income, wherein it was brought to his notice that the income from the other sources of Rs.14,16,609/- as disclosed in his Form 26AS was not included in the return of income. The Ld. DR submitted that the AO/CPC, Bengaluru, vide another communication dated 23.10.2018, had brought to the notice of the assessee another inconsistency in his return of income, and the assessee had responded to the same. The Ld. DR submitted that the AO/CPC, Bengaluru, after considering the infirmities in the return of income, had even advised the assessee to file a correct return of income.

10.

Be that as it may, I find that the appeal filed by the assessee before the CIT(A) involves an inordinate delay of 1503 days. As is discernible from the “Form 35” filed by the assessee before CIT(A), the assessee at S.no.15 had stated that the delay of 1503 days in filing the appeal had crept in because she

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could not download the intimation issued under section 143(1) of the Act, which was uploaded by the AO/CPC on 11.01.2019. Accordingly, it was stated by the assessee that as the delay in filing the appeal was not attributable to any delay or laches on her part but because of the aforesaid reason, which was beyond her control, therefore, in all fairness and interest of justice, the same be condoned. The Ld. AR to buttress his contention that the delay involved in the present appeal merits condonation had pressed into service the order of the ITAT Bangalore Bench in the case of Shri Arthur Bernard Sebastine Pais v. DCIT in ITA No. 1683/BANG/2019 dated 16.10.2019. Also, the Ld. AR had pressed into service the order of the Hon’ble Supreme Court in the case of Senior Bhosale Estate (HUF) v. ACIT in Civil Appeal No. 6671 to 6676/ 2010, dated 07.11.2019. Elaborating on his contention, the Ld.AR submitted that the Hon’ble Supreme Court in its aforesaid order had condoned the delay of 1754 days as the appellant had remained unaware of the impugned order.

11.

I have thoughtfully considered the contentions advanced by learned authorised representatives of both parties in the backdrop of the aforesaid judicial pronouncements.

12.

At the threshold, I may herein observe that the delay of 1503 days involved in the appeal filed by the assessee before the CIT(A) is undoubtedly inordinate. Apart from that, I am of the view that the assessee had failed to come up with any plausible explanation regarding the aforesaid inordinate delay in filing the appeal. Apropos, the claim of the assessee that she could not

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download the intimation issued by the AO/CPC, Bengaluru, issued under section 143(1) of the Act dated 11.01.2019, for a period of as long as four years, I find the same not only incomprehensible but also difficult to fathom. Although the Ld.AR has drawn my attention to the screenshot, which reveals that the intimation issued by AO/CPC, Bengaluru under section 143(1) of the Act could not be downloaded, but had failed to place on record any material, which could irrefutably evidence the efforts she had put up for obtaining the copy of the aforesaid intimation during the aforesaid period of four years. The Ld. AR has not produced before me any such material, which would reveal that the assessee had approached any of the income tax authorities, A.O/CPC, Bengaluru; or filed any grievance that she had been divested of her right to assail the adjustments made vide intimation issued under Section 143(1) of the Act, dated 11.01.2019 by the AO/CPC by filing an appeal before the CIT(A), for the reason that the copy of the impugned Intimation issued by the A.O/CPC, Bengaluru, based on which the impugned addition and the consequential exorbitant demand of Rs.6,36,000/- was raised in her hands was not being made available to her. I am unable to persuade myself to subscribe to the unsubstantial claim of the Ld.AR that the delay in filing the present appeal by the assessee had crept in for no fault on her part. In fact, I will mince no words in observing that as the present case before me is a case of gross negligence and the lackadaisical approach adopted by the assessee, which had resulted in an inordinate delay of 1503 days in filing the appeal before the CIT(A), and, thus, does not merit condonation. I have given thoughtful consideration to the

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judicial pronouncements that have been pressed into service by the Ld.AR and am of the view that the same being distinguishable on facts will not assist the case of the present assessee before me. I am of the view that though a judicial and liberal approach should be adopted for condoning the delay involved in filing of an appeal by an appellant and the same should normally be condoned, but the law is well settled that while courts are expected to adopt a liberal approach in considering petitions for condonation of delay where sufficient cause is shown, such liberality cannot be extended to condone inordinate delay where the explanation is vague, casual, or lacking in bona fides. My aforesaid view is supported by the order of the Hon’ble Supreme Court in Office of the Chief Post Master General & Ors. v. Living Media India Ltd. & Anr. (2012) 348 ITR 7 (SC), wherein it was held as under:

“It is not that a delay of a few days is to be condoned automatically. The law of limitation is founded on public policy. The courts have to exercise discretion only when sufficient cause is shown and not in a routine manner.” Similarly, in Basawaraj & Anr. v. Special Land Acquisition Officer (2013) 14 SCC 81, the Hon’ble Supreme Court had observed, as under:

“The expression ‘sufficient cause’ should be construed strictly and not liberally merely to benefit a litigant who is negligent. Delay cannot be condoned merely because the Government or a private party has a good case on merits. The applicant must explain each day’s delay satisfactorily.”

Further, the Hon’ble Supreme Court in P.K. Ramachandran v. State of Kerala (1997) 7 SCC 556 has held, as under:

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“Law of limitation may harshly affect a particular party but it has to be applied with all its rigour when the statute so prescribes. Courts have no power to extend the period of limitation on equitable grounds.”

Accordingly, by applying the above principles to the present case, I find that the explanation offered by the assessee regarding the reason leading to the inordinate delay in filing the appeal before the CIT(A) does not inspire any confidence and is devoid and bereft of any substance. I further find that the Hon’ble Supreme Court in Union of India v. Popular Construction Co. (2001) 8 SCC 470, has observed that limitation provisions are based on sound public policy — to ensure certainty, finality, and avoidance of stale claims. In the instant case, as the assessee has failed to come forth with any plausible explanation leading to the inordinate delay of 1503 days involved in the appeal filed before the CIT(A), therefore, as the said delay of a substantial period is also not backed up by any justifiable reason, I am constrained to uphold the well reasoned view taken by the CIT(A), who had dismissed the appeal on the ground of limitation.

15.

Resultantly, the appeal filed by the assessee, being devoid and bereft of any substance, is dismissed.

Order pronounced in the open court on 18th February, 2026.

Sd/- (रिीश सूद) (RAVISH SOOD) न्याधयक सदस्य/JUDICIAL MEMBER Dated: 18.02.2026 *Giridhar, Sr.PS

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आदेश की प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:- 1. निर्धाररती/ The Assessee : Audrey Bernice Roy Plot No. 274, Sector – 3 Opposite Hotel Vyasakhi Parlour 2nd Lane, MVP Colony Visakhapatnam – 530017 Andhra Pradesh 2. रधजस्व/ The Revenue : Income Tax Officer – Ward – 2(5) Visakhapatnam – 530016 Andhra Pradesh 3. The Principal Commissioner of Income Tax 4. नवभधगीयप्रनतनिनर्, आयकरअपीलीयअनर्करण, नवशधखधपटणम /DR,ITAT, Visakhapatnam 5. The Commissioner of Income Tax 6. गधर्ाफ़धईल / Guard file आदेशधिुसधर / BY ORDER Digitally signed by V S S V S S GIRIDHAR GIRIDHAR BABU MEKALA BABU MEKALA Date: 2026.03.04 10:05:09 +05'30' Sr. Private Secretary ITAT, Visakhapatnam

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AUDREY BERNICE ROY,VISAKHAPATNAM vs. INCOME TAX OFFICER, VISAKHAPATNAM