HUBLI SATHYANARAYANASETTY CHANDRAPPA,HUBLI vs. INCOME TAX OFFICER, WARD 2(1), HUBLI

This is an appeal filed by the assessee against the order passed by the ADDL/JCIT (A)-4 Mumbai Dated: 19/08/2024 DIN & Order No : ITBA/APL/S/250/2024-25/1067742006(1) for the assessment year 2021- 22.

At the outset, we note that there was a delay of 144 days in filing the appeal before the learned CIT(A) by the assessee. The assessee, in its condonation petition before the learned CIT(A), explained that certain items of income were reported in the Tax Audit Report, which were duly offered for tax. However, the Centralized Processing Centre (CPC), while processing the return under Section 143(1) of the Income Tax Act, added ₹28,61,528/- to the total income of the assessee. Following this, the assessee considered two options: either avoid filing the appeal before the learned CIT(A) or move a rectification application under Section 154 of the Act. Additionally, the assessee is an 85-year-old senior citizen, and due to health-related issues associated with old age, the assessee could not file the appeal within the stipulated time. However, the learned CIT(A) was not convinced by the reasons provided by the assessee for the delay and, therefore, rejected the appeal of the assessee.

The learned Authorized Representative (AR) for the assessee contended that the CPC had made a double addition under Section 143(1) of the Income Tax Act, which was subsequently confirmed by the learned CIT(A) when the appeal was rejected. According to the learned AR, a meritorious case should not be rejected on technical grounds, and as such, the matter deserves to be heard on its merits. The learned AR further prayed before us that the delay in filing the appeal before the learned CIT(A) should be condoned. Additionally, the AR requested that the matter be remitted back to the file of the Assessing Officer (AO) for fresh adjudication after necessary verification, particularly concerning the issue of double addition of the same income.