SEEMA SINGH LEGAL HEIR OF SANJAY SINGH,DELHI vs. ITO, WARD-58(1), DELHI

ITA 6148/DEL/2025Status: DisposedITAT Delhi30 October 2025AY 2018-19Bench: Sh. Satbeer Singh Godara (Judicial Member)3 pages
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What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal by the assessee's legal heir, citing the principle of substantial justice. The case was restored to the CIT(A)/NFAC for fresh adjudication, with a directive to first decide the appellant's status as the legal representative.

What were the facts?

The assessee's legal heir's appeal for Assessment Year 2018-19 was filed against an order passed under Section 147 r.w.s. 144 of the Income Tax Act. The delay in filing the lower appeal was 227 days and the CIT(A)/NFAC refused to condone it.

What were the issues?

Whether the delay in filing the appeal before the CIT(A)/NFAC should be condoned and if the appellant has the status of a legal representative.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 2(29),Section 2(11)

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

Before: Sh. Satbeer Singh Godara

Hearing: 30.10.2025Pronounced: 30.10.2025

This assessee’s/alleged legal heir’s appeal for Assessment Year 2018-19, arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1079155441(1) dated 31.07.2025, in proceedings u/s 147 r.w.s. 144 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)/NFAC has refused to condone delay of 227 days in filing of the assessee’s lower appeal instituted on 04.12.2023 against the Assessing Officer’s assessment framed on 22.03.2023

2 Late Sanjay Singh L/H Seem Singh the

The order continues below.

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