SHABD PRATAP SATSANG,SHABD PRATAP ASHRAM vs. NATIONAL FACELESS APPEAL CENTRE, DELHI, DELHI

ITA 542/AGR/2025Status: DisposedITAT Agra25 March 2026AY 2017-18Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)4 pages
AI SummaryAllowed

What did the Tribunal hold?

The ITAT held that the CIT(A) wrongly refused to condone the delay, emphasizing that substantial justice should not be denied on technical grounds and that the period of the COVID-19 pandemic should be excluded for limitation purposes as per Supreme Court directives. The tribunal condoned the delay and restored the matter to the CIT(A) for a fresh decision on merits.

What were the facts?

The assessee's appeal against an assessment order was dismissed by the CIT(A) due to a significant delay of 1302 days in filing, and the CIT(A) refused to condone the delay. The assessee cited the severe injury and subsequent recovery of their Chartered Accountant as the reason for the delay. The ITAT reviewed the case, considering the impact of the COVID-19 pandemic on limitation periods.

What were the issues?

The key legal issue was whether the CIT(A) was justified in refusing to condone a 1302-day delay in filing an appeal, especially considering the reasons provided by the assessee and the Supreme Court's directives regarding the COVID-19 pandemic's impact on limitation periods.

Which sections of the Income-tax Act were involved?

Section 143(1),Section 246A,Section 249(2),Section 249(3),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AGRA (DB

Before: SHRI S. RIFAUR RAHMAN & SHRI SUNIL KUMAR SINGH

For Appellant: Shri Rajendra Sharma, Adv
For Respondent: Shri Anil Kumar, Sr. DR
Hearing: 18.02.2026Pronounced: 18.02.2026

This appeal has been preferred against the impugned order dated 25.08.2025 passed in appeal No NFAC/2016-17/10188904 by the ld. Commissioner of Income Tax/ National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as the “CIT(A) u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) for the A.Y. 2017-18, wherein ld CIT(A) has dismissed assessee’s appeal upon rejection of assessee’s prayer for the condonation of delay.

2.

Assessee’s adjournment prayer was rejected. Perused the records. Heard ld representatives for both the parties.

3.

At the very outset it is noticed that first appeal was filed on 18.11.2022 against the assessment order dated 27.03.2019 passed u/s. 143(1) of the Act by a delay of about 1302 days. The reasons for the delay

The order continues below.

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