People Education and Economic Development Society (PEEDS) v. ITO

100 ITD 87Income Tax Appellate Tribunal2006#869 most cited

What is People Education and Economic Development Society (PEEDS) v. ITO authority for?

When substantial justice and procedural technicalities are in conflict, especially in cases involving non-deliberate delay, the cause of substantial justice must be prioritized. The opposing party cannot claim a vested right to benefit from injustice due to such delays.

121

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

People Education and Economic Development Society v ITO · PEEDS v ITO · 100 ITD 87 · ITAT Chennai · condonation of delay · delay in filing appeal · Section 253(5) · substantial justice · non-deliberate delay · reasonable cause · Mst. Katiji principle · procedural technicalities

Sections most often in play

Section 253(5)Section 250Section 143(3)Section 144Section 147Section 154Section 271(1)(c)Section 69A

Issues it is cited on

section 253(5)section 51section 80ibsection 271aabreasonable causesection 139(4)delay in filing appealcondonation of delaysection 274section 253section 153dsection 154

Judgments citing People Education and Economic Development Society (PEEDS) v. ITO

VENKATESH SANJEEVAIAH ,BANGALORE vs. INCOME TAX OFFICER, WARD-5(1)(1), BENGALURU

In the result, appeal filed by the assessee is partly allowed for Statistical purposes

ITA 2498/BANG/2025[2016-17]Status: DisposedITAT Bangalore30 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2016-17

For Appellant: Sri Narendra Sharma, A.RFor Respondent: Sri Subramanian, D.R
Section 250Section 253(5)Section 271F

…authority of law. Therefore, if we refuse to condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. 6.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 6.4 The next question may arise whether delay was excessive or…

SHRI BHARAT NAVINCHANDRA GALA ,MUMBAI vs. ITO WARD 41(3)(1), MUMBAI

In the result, appeal filed by assessee stands partly allowed for statistical purposes

ITA 506/MUM/2025[2012-13]Status: DisposedITAT Mumbai20 Feb 2026AY 2012-13

Bench: Smt. Beena Pillai ()

Section 154

…lay caused in filing appeal before this tribunal, the lapse that occurred on behalf of the representative cannot be attributed to the assessee for which assessee could be punished. In case of People Education & Economic Development Society Vs. ITO reported in 100 ITD 87 (TM) (Chen), it was held that; “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 2.5. The next question that arises is whether delay was excessive…

KOWLANAHALLI NINGEGOWDA SOMASHEKAR,BANGALORE vs. INCOME TAX OFFICER, WARD-5(2)(3), BANGALORE

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 1045/BANG/2025[2021-13]Status: DisposedITAT Bangalore12 Feb 2026AY 2021-13

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2012-13

For Appellant: Ms. Pooja Maru, A.RFor Respondent: Sri Balusamy N., D.R
Section 250Section 253(5)

…authority of law. Therefore, if we refuse to condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. 6.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 6.4 The next question may arise whether delay was excessive or…

BIJU PAPPACHAN,KERALA vs. AO, BANGALORE

In the result, the appeal filed by the assessee is allowed

ITA 2153/BANG/2025[2019-20]Status: DisposedITAT Bangalore09 Feb 2026AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2019-20

For Appellant: Ms. Akshatha Prasad, A.RFor Respondent: Sri Ganesh R Ghale, D.R
Section 250

…authority of law. Therefore, if we refuse to condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. 6.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 6.4 The next question may arise whether delay was excessive or…

JAMBALLI SHIVAPPA ,SHIVAMOGGA vs. INCOME TAX OFFICER, WARD-2, SHIMOGA

In the result, appeal filed by the assessee is allowed

ITA 2140/BANG/2025[2017-18]Status: DisposedITAT Bangalore09 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Sri V. Narendra Sharma, A.RFor Respondent: Sri Ganesh R Ghale, A.R
Section 250Section 253(5)

…i Jamballi Shivappa, Shivamogga Page 8 of 12 condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. 6.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 6.4 The next question may arise whether delay was excessive or…

PRATIK MAYUR DOSHI,PALGHAR vs. INCOME TAX OFFICER, JURISDICTION WARD 1, PALGHAR, PALGHAR

In the result, appeal filed by the assesse stands partly allowed for statistical purposes

ITA 7516/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Feb 2026AY 2017-18

Bench: Smt. Beena Pillai ()

…ctor Land Acquisition Vs. Mst. Katiji & Ors., reported in (1987) 167 ITR 471 in support of his contentions. 3.1. We refer to the Third Member decision of Hon’ble Chennai, ITAT in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein it was held that "when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay". 3.2. It is also necessary to ascertain whether there was…

SHILA ASHOK SHAH FOUNDATION,MUMBAI vs. CIT EXEMPTIOM, MUMBAI

In the result, appeal of the assessee stands allowed

ITA 6764/MUM/2025[2025-26]Status: DisposedITAT Mumbai19 Jan 2026AY 2025-26

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 11Section 11(1)(c)Section 12ASection 2

…ector Land Acquisition Vs. Mst. Katiji & Ors., reported in (1987) 167 ITR 471 in support of his contentions. 3.2. We refer to the Third Member decision of Hon’ble Chennai, ITAT in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein it was held that "when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay". 3.3. It is also necessary to ascertain whether there was e…

SANTOSH KUMAR RAMLAXMAN YADAV,MUMBAI vs. INCOME TAX OFFICER WARD 42(3)(3), MUMBAI

In the result, appeal filed by assessee is allowed for statistical purposes

ITA 5123/MUM/2025[2016-2017]Status: DisposedITAT Mumbai31 Dec 2025AY 2016-2017

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 144Section 148Section 151ASection 69

…ector Land Acquisition Vs. Mst. Katiji & Ors., reported in (1987) 167 ITR 471 in support of his contentions. 4.2. We refer to the Third Member decision of Hon’ble Chennai, ITAT in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein it was held that "when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay". 8 I.T.A. No. 5123/Mum/2025 4.3. It is also necessary to a…

JM FINANCIAL FOUNDATION ,MUMBAI vs. ITO (EXEMPTION)-WARD-1(4), MUMBAI

In the result, appeal filed by assessee stands at for statistical purposes

ITA 6558/MUM/2025[2018-19]Status: DisposedITAT Mumbai29 Dec 2025AY 2018-19

Bench: Smt. Beena Pillai () & Shri Makarand Vasant Mahadeokar ()

Section 11Section 11(2)Section 147Section 148Section 151A

…ctor Land Acquisition Vs. Mst. Katiji & Ors., reported in (1987) 167 ITR 471 in support of his contentions. 5.5. We refer to the Third Member decision of Hon’ble Chennai, ITAT in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein it was held that "when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay". 5.6. At this juncture, it is also necessary to ascertain…

JM FINANCIAL FOUNDATION ,MUMBAI vs. ITO (EXEM) WARD 1(4), MUMBAI

In the result, appeal filed by assessee stands at for statistical purposes

ITA 6557/MUM/2025[2017-18]Status: DisposedITAT Mumbai29 Dec 2025AY 2017-18

Bench: Smt. Beena Pillai () & Shri Makarand Vasant Mahadeokar ()

Section 11Section 11(2)Section 147Section 148Section 151A

…ctor Land Acquisition Vs. Mst. Katiji & Ors., reported in (1987) 167 ITR 471 in support of his contentions. 5.5. We refer to the Third Member decision of Hon’ble Chennai, ITAT in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein it was held that "when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay". 5.6. At this juncture, it is also necessary to ascertain…

SWAPNGANDHA SANJAY PARAB ,MUMBAI vs. INCOME TAX OFFICER WARD 42(3)(4), MUMBAI

In the result, appeal filed by assessee is allowed for statistical purposes

ITA 4614/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Dec 2025AY 2017-18

Bench: Smt. Beena Pillai () & Shri Makarand Vasant Mahadeokar ()

Section 271A

…ector Land Acquisition Vs. Mst. Katiji & Ors., reported in (1987) 167 ITR 471 in support of his contentions. 3.2. We refer to the Third Member decision of Hon’ble Chennai, ITAT in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein it was held that "when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be 3 I.T.A. No. 4614/Mum/2025 preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay". 3.3. It is also necessary to a…

SATBIR KUMAR SARLIA,THANE vs. WARD 3(2) THANE, THANE

In the result, appeal filed by the assessee stands partly allowed for statistical purposes

ITA 5824/MUM/2025[2011-2012]Status: DisposedITAT Mumbai05 Dec 2025AY 2011-2012

Bench: Smt. Beena Pillai () & Ms. Padmathy S. ()

Section 144Section 154Section 250Section 253Section 269Section 271DSection 27I

…ector Land Acquisition Vs. Mst. Katiji & Ors., reported in (1987) 167 ITR 471 in support of his contentions. 4.2. We refer to the Third Member decision of Hon’ble Chennai, ITAT in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein it was held that "when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay". 4.3. It is also necessary to ascertain whether there was…

M/S. RUKMANI FINANCE PVT LTD.,,BENGALURU vs. INCOME TAX OFFICER, WARD-5(1)(4), BANGALORE

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 919/BANG/2025[2017-18]Status: DisposedITAT Bangalore26 Sept 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year :2017-18 M/S. Rukmani Finance Pvt. Ltd. No.84, 5Th Floor, Manish Tower Ito J.C. Road Vs. Ward 5(1)(4) Bengaluru 560 002 Bengaluru Pan No : Aaacr9552P Appellant Respondent Appellant By : Sri T. Srinivasa, A.R. Respondent By : Sri Subramanian, D.R. Date Of Hearing : 30.06.2025 Date Of Pronouncement : 26.09.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ld. Cit(A)/Nfac Dated 31.05.2023 Vide Din & Order No. Itba/Nfac/S/250/2023-24/1053354784(1) Passed U/S. 250 Of The Income Tax Act, 1961 (In Short “The Act”) For The Assessment Year 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: M/S. Rukmani Finance Pvt. Ltd., Bengaluru Page 2 Of 11

For Appellant: Sri T. Srinivasa, A.RFor Respondent: Sri Subramanian, D.R
Section 250Section 253(5)

…e delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. M/s. Rukmani Finance Pvt. Ltd., Bengaluru Page 8 of 11 6.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 6.4 The next question may arise whether delay was excessive or…

K N GOPALA HEGGADE HUF,CHIKKMAGALUR vs. INCOME TAX OFFICER, WARD-1, CHIKMAGALUR

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 699/BANG/2025[2020-21]Status: DisposedITAT Bangalore25 Sept 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Sri Gowrish Bhargav K.V., A.RFor Respondent: Sri Balusamy N., D.R
Section 250Section 253(5)

…authority of law. Therefore, if we refuse to condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. 6.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to K.N. Gopala Heggade HUF, Chikkmagalur Page 11 of 13 have vested right in injustice being done because of non-deliberate delay”. 6.4 The nex…

BASAVANNEPPA GULEDAKERI,HAVERI vs. INCOME TAX OFFICER, WARD-2, HAVERI

In the result, the appeal filed by the assessee is allowed

ITA 605/BANG/2025[2017-18]Status: DisposedITAT Bangalore15 Sept 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year :2017-18

For Appellant: Shri Sandeep Chalapathy, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing
Section 115BSection 250Section 251Section 253(5)Section 69A

…authority of law. Therefore, if we refuse to condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. 6.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 6.4 The next question may arise whether delay was excessive or…

SETTIKERE SHANKARAPPA MURUGESHAIH ,TUMKUR vs. INCOME TAX OFFICER, WARD-1, TUMAKURU

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 521/BANG/2025[2016-17]Status: DisposedITAT Bangalore15 Sept 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Sri Tarun Kumar M.K., A.RFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing
Section 250Section 253(5)

…authority of law. Therefore, if we refuse to condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. 6.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 6.4 The next question may arise whether delay was excessive or…

VANIGOTA SUGAR TRADING COMPANY ,VIJAPUR vs. INCOME TAX OFFICER, WARD-1 & TPS , BIJAPUR

In the result, the appeal of the assessee is allowed

ITA 2545/BANG/2024[2017-18]Status: DisposedITAT Bangalore15 Sept 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Smt. Pratibha R., A.RFor Respondent: Sri Subramanian S., D.R
Section 253(5)Section 263

…authority of law. Therefore, if we refuse to condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. 4.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 4.4 The next question may arise whether delay was excessive or…

GEETHA MAHADEV GOWDA,BENGALURU vs. INCOME TAX OFFICER, WARD-2(1)(3), BANGALORE

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 547/BANG/2025[2016-17]Status: HeardITAT Bangalore04 Sept 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2016-17

For Appellant: NONEFor Respondent: Sri Shivanand H Kalakeri, D.R
Section 250Section 253(5)

…authority of law. Therefore, if we refuse to condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. 8.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. Smt. Geetha Mahadev Gowda, Bangalore Page 7 of 8 8.4 The next qu…

K N DILEEP,BANGALORE vs. INCOME TAX OFFICER, WARD-1, RAMNAGAR

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 1346/BANG/2025[2017-18]Status: HeardITAT Bangalore04 Sept 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Sri Vijay Simha, A.RFor Respondent: Shri Balusamy N., D.R
Section 250Section 253(5)

…authority of law. Therefore, if we refuse to condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. 4.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 4.4 The next question may arise whether delay was excessive or…

UMBRELLA FOUNDATION ,BANGALORE vs. COMMISSIONER OF INCOME TAX(EXEMPTIONS), BANGALORE

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 897/BANG/2025[NA]Status: DisposedITAT Bangalore03 Sept 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: Na

For Appellant: Smt. Suman Lunkar, A.RFor Respondent: Sri Murali Mohan, D.R
Section 253(5)Section 80G

…authority of law. Therefore, if we refuse to condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority. 4.3 Further, in the case of People Education & Economic Development Society Vs/ ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 4.4 The next question may arise whether delay was excessive or…

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