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

100 ITD 87Income Tax Appellate Tribunal2006#858 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 366,470 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

Marine Drishti and Coastal Foundation, Goa vs. CIT (Exemption), Bangalore, Bengaluru

In the result, appeal filed by the assessee in ITA

ITA 456/BANG/2025[2024-25]Status: DisposedITAT Bangalore31 Jul 2025AY 2024-25

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Dr. K. Shivaram, Sr. AdvocateFor Respondent: Sri E. Shridhar, D.R
Section 12ASection 253Section 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. 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…

Marine Drishti and Costal Foundation, Goa vs. CIT (Exemption), Bangalore, Bengaluru

In the result, appeal filed by the assessee in ITA

ITA 455/BANG/2025[2024-25]Status: DisposedITAT Bangalore31 Jul 2025AY 2024-25

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Dr. K. Shivaram, Sr. AdvocateFor Respondent: Sri E. Shridhar, D.R
Section 12ASection 253Section 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. 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…

Marine Drishti and Costal Foundation, Goa vs. CIT (Exemption), Bangalore, Bengaluru

In the result, appeal filed by the assessee in ITA

ITA 454/BANG/2025[2024-25]Status: DisposedITAT Bangalore31 Jul 2025AY 2024-25

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Dr. K. Shivaram, Sr. AdvocateFor Respondent: Sri E. Shridhar, D.R
Section 12ASection 253Section 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. 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…

Narshi Gopalji Mange, Mumbai vs. ITO 27(2)(4), Mumbai

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

ITA 2064/MUM/2024[2013-2014]Status: DisposedITAT Mumbai31 Jul 2025AY 2013-2014

Bench: Smt. Beena Pillai () & Shri Om Prakash Kant ()

Section 143(1)Section 143(2)Section 69A

…fessional, the assessee was informed about the appeal being passed by the Ld.CIT(A). This being the position, it constitutes sufficient cause for filing the appeals belatedly. 5.4. 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 technicalities are pitted against each other, the cause of substantial justice deserves to be 7 ITA No. 2064/Mum/2024; A.Y. 2013-14 Narshi Gopalji Mange preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”. 5.5. The next…

Shri Guru Gajadandeshwara Charitable Trust, Devarabhupur, Lingasagur vs. The Income Tax Officer, Exemption, Exemption Ward-1, Kalburgi

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

ITA 502/BANG/2025[2025-26]Status: DisposedITAT Bangalore30 Jul 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: Na Shri Guru Gajadandeshwara Charitable Trust 1 Devarabhupur Post Devabhupur Cit (Exemption) Lingasugur Vs. Ward-1 Raichur 584 139 Kalburgi Karnataka Pan No : Aazts9450P Appellant Respondent Appellant By : Sri Ramanagowda S Gowdari, A.R. Respondent By : Sri Sridhar E., D.R. Date Of Hearing : 15.05.2025 Date Of Pronouncement : 30.07.2025 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 (Exemption) Dated 26.9.2024 Vide Din & Order No. Itba/Exm/F/Exm45/2024-25/1069118346(1) Cancelling The Approval U/S 80G Of The Act Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sri Ramanagowda S Gowdari, A.RFor Respondent: Sri Sridhar E., 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. 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…

Siddiq Hussain Delvi, Bengaluru vs. Income Tax Officer, Ward-1(2)(2), Bengaluru

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

ITA 2374/BANG/2024[2017-18]Status: DisposedITAT Bangalore30 Jul 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2017-18 Siddiq Hussain Delvi No.127 L. No.1St Floor 6Th Street, Oph Road Shivaji Nagar Vs. Ito Ward 1(2)(2) Bengaluru 560 051 Bengaluru Pan No : Aveps62323P Appellant Respondent Appellant By : Sri Phani Kumar, A.R. Respondent By : Sri Ashwin D Gowda, D.R. Date Of Hearing : 28.07.2025 Date Of Pronouncement : 30.07.2025

For Appellant: Sri Phani Kumar, A.RFor Respondent: Sri Ashwin D Gowda, D.R
Section 226(3)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…

Marasanige Chinne Gowda Santhosh, Chikmagalur vs. Income Tax Officer, Ward-1, Chikmagalur

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

ITA 324/BANG/2025[2017-18]Status: DisposedITAT Bangalore22 Jul 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2017-18 Marasanige Chinne Gowda Santhosh 189, Marasanigi Village Post Mudigere Ito Chikmagalur Taluk Vs. Ward 1 Chikmagalur 577 124 Chikmagalur Karnataka Pan No : Bhzps2254R Appellant Respondent

For Appellant: Sri Gireesha A.RFor Respondent: Sri Subramanian S., 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 MarasanigeChinneGowdaSanthoshChikmagalur Page 7 of 13 have vested right in injustice being done because of non-deliberate delay”. 6.4 The n…

M/S Hussain Multispeciality Hospital, Bijapur vs. The Income Tax Officer, Ward-1, Vijayapur

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

ITA 2387/BANG/2024[2016-17]Status: DisposedITAT Bangalore15 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 250Section 40

…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 in…

Yuva Chintana Foundation, Bengaluru vs. Income Tax Officer, Exemptions Ward 2, Bengaluru

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

ITA 301/BANG/2025[2021-22]Status: DisposedITAT Bangalore09 Jul 2025AY 2021-22

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2021-22

For Appellant: Shri Anoop Agarwal, CAFor Respondent: Shri Subramanian .S, JCIT-DR
Section 250Section 253(5)

…r than technicality in deciding the issue. Therefore, in our opinion, by preferring the substantial justice, the delay of 41 days has to be condoned. Page 7 of 14 3.8 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”. 3.9 The next question may arise whether delay was excessive or…

Thrissur District Police Co Operative Society Ltd, Thrissur vs. Income Tax Officer, Thrissur

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

ITA 409/COCH/2024[2016-17]Status: DisposedITAT Cochin19 May 2025AY 2016-17

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

For Appellant: Shri M.Ramdas, CAFor Respondent: Smt. Leena Lal, Sr. A.R
Section 154Section 250Section 253(5)

…justice rather than technicality in deciding the issue. Therefore, in our opinion, by preferring the substantial justice, the delay of 96 days has to be condoned. 3.6 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”. 3.7 The next question may arise whether delay was excessive or…

Thrissur District Police Co Operative Society Ltd, Thrissur vs. Income Tax Officer, Thrissur

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

ITA 408/COCH/2024[2014-15]Status: DisposedITAT Cochin19 May 2025AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

For Appellant: Shri M.Ramdas, CAFor Respondent: Smt. Leena Lal, Sr. A.R
Section 154Section 250Section 253(5)

…justice rather than technicality in deciding the issue. Therefore, in our opinion, by preferring the substantial justice, the delay of 96 days has to be condoned. 3.6 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”. 3.7 The next question may arise whether delay was excessive or…

Karnataka Chinmaya Seva Trust, Bengaluru vs. DCIT-(Exemptions) Circle-1, Bangalore

In the result, appeal filed by the assessee is allowed

ITA 1267/BANG/2024[2016-17]Status: DisposedITAT Bangalore14 May 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessmentyear:2016-17

For Appellant: Sri N. Suresh, A.RFor Respondent: Ms. Neha Sahay, D.R
Section 250Section 253(5)

…justice rather than technicality in deciding the issue. Therefore, in our opinion, by preferring the substantial justice, the delay of 41 days has to be condoned. 6.5 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”. 6.6 The next question may arise whether delay was excessive or…

Abdul Hakeem, Gulbarga vs. Income Tax Officer, Ward-1 & Tps, Gulbarga

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

ITA 31/BANG/2025[2017-18]Status: DisposedITAT Bangalore22 Apr 2025AY 2017-18

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

For Appellant: Sri Gokul H.R., A.RFor Respondent: Ms. Neha Sahay, 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…

Indira Veluri, Bangalore vs. Income Tax Officer, Ward-4(2)(3), Bangalore

In the result, the appeal is allowed

ITA 2513/BANG/2024[2021-2022]Status: DisposedITAT Bangalore21 Apr 2025AY 2021-2022

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2021-22

For Appellant: Sri Pavan Kumar, A.RFor Respondent: Sri Ganesh R Gale, Standing counsel for department
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. 5.3 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”. 5.4 The next question may arise whether delay was excessive or…

Louella Maria Albuquerque, Mangalore vs. Income Tax Officer, Ward-2(5), Mangalore

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

ITA 2487/BANG/2024[2014-15]Status: DisposedITAT Bangalore21 Apr 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear:2014-15

For Appellant: Sri Srinivas Kamath, A.RFor Respondent: Ms. Neha Sahay, 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…

Bangalore Stock Exchange Customer Protection Fund, Chennai vs. Income Tax Officer, (E), Ward-1, Bengaluru

In the result, both the appeals filed by the assessee are

ITA 2246/BANG/2024[2017-18]Status: DisposedITAT Bangalore21 Apr 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Manasa Ananthan, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 250Section 253(5)Section 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 ITA No.2245/Bang/2024 Bangalore Stock Exchange Customer Protection Fund, Chennai Page 13 of 17 have vested right in injustice being done be…

Bangalore Stock Exchange Customer Protection Fund, Chennai vs. Income Tax Officer, (E) Ward-1, Bengaluru

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 2245/BANG/2024[2016-17]Status: DisposedITAT Bangalore21 Apr 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Manasa Ananthan, A.RFor Respondent: Smt. Neha Sahay, 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 Bangalore Stock Exchange Customer Protection Fund, Chennai Page 13 of 17 have vested right in injustice being done because of non-deliberate…

Hitesh Suresh Jadhav, Kalher, Thane vs. ITO, Ward 1(5), Kalyan

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

ITA 771/MUM/2025[2017-18]Status: DisposedITAT Mumbai28 Mar 2025AY 2017-18

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(2)Section 144Section 250Section 69A

…use for delay. The Court/authority has to examine whether the sufficient cause has been shown by the party for condoning the delay, and whether such cause is reasonable or not. 2.3 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”. 2.4 The next question that arises is whether delay was excessive…

India Land and Properties Limited (Since Merged With Equinox India Developments Ltd Formerly Known As India Bulls Real Estate Limited), Mumbai vs. DCIT Central Circle 6(4), Mumbai

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

ITA 426/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 Mar 2025AY 2016-17

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

Section 226

…in filing appeal before this Tribunal, and the lapse occurred on behalf of the representatives which cannot be attributed to the assessee, for which assessee could be punished. 5.1 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”. 6. The next question that arises is, whether delay was excessive…

Capco Finance and Investment Private Limited, Mumbai vs. ITO Ward 15 1 1 Mumbai, Mumbai

In the result appeal filed by the assessee stands allowed on

ITA 44/MUM/2025[2012-13]Status: DisposedITAT Mumbai28 Feb 2025AY 2012-13

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

Section 249(2)Section 271FSection 69

…was subsequently when the office resumed to normally the assessee realised about the lapse. This being the reason, it constitutes sufficient cause for filing the appeal belatedly. 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". 3.5 The next question that arises is whether delay was excessive…