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“condonation of delay”

AppealsSection 249Section 24912,312 judgments

The decision most relied on for condonation of delay is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 judgments on BharatTax.

Leading authorities on condonation of delay

Collector, Land Acquisition v. Mst. Katiji
167 ITR 471 · 1987 · Supreme Court
3,926
citing judgments

Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.

Collector, Land Acquisition, Anantnag & Anr. v. Mst. Katiji & Ors.
2 SCC 107 · 1987 · Supreme Court
451
citing judgments

Courts must adopt a liberal approach when considering applications for condonation of delay, preferring to decide cases on their merits rather than allowing technicalities of limitation to scuttle justice. This principle applies to ensure the substantive rights of parties are not defeated by minor delays.

Balakrishnan v. M. Krishnamurthy
7 SCC 123 · 1998 · Supreme Court
368
citing judgments

The Supreme Court outlines the principles for condoning delay in filing appeals, stating that a litigant's lapse is not always a bar if the explanation is bona fide and not a dilatory strategy. Courts should show utmost consideration to suitors and prioritize substantial justice unless the delay is deliberately to gain time.

Vishin Meghani v. DCIT & Anr
398 ITR 250 · 2017 · High Court
291
citing judgments

This case is cited as an authority supporting the condonation of delay in filing income tax appeals, particularly when an assessee presents a request for such condonation.

Concord of India Insurance Co. Ltd. v. Smt. Nirmala Devi and Others
118 ITR 507 · 1979 · Supreme Court
268
citing judgments

For condoning delay, the term 'sufficient cause' must be interpreted liberally and purposively to advance justice. Delay not tainted by mala fides, gross negligence, or recklessness, and based on honestly obtained legal advice, constitutes sufficient cause.

Inder Singh v. State of Madhya Pradesh
2025 INSC 382 · 2025 · Supreme Court
267
citing judgments

Non-deliberate procedural delays caused by circumstances beyond control must be condoned in the interest of substantial justice, even if the delay is significant, such as over 1500 days.

Vedabhai v. Santaram
253 ITR 798 · 2002 · Supreme Court
262
citing judgments

When substantial justice and technical considerations are in conflict, substantial justice should be prioritized. Condoning delay requires a cautious approach without malafide or dilatory tactics, and 'sufficient cause' should be interpreted liberally to advance substantial justice.

Sreenivas Charitable Trust v. Dy. CIT
280 ITR 357 · 2006 · High Court
182
citing judgments

The expression "sufficient cause" for condoning delay in filing appeals must receive a liberal and purposive construction. This approach aims to advance substantial justice, which is of paramount importance.

Judgments citing condonation of delay

Chiranjjeevi Wind Energy Ltd., Coimbatore vs. ACIT, Corporate Circle-1, Coimbatore

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

ITA 1857/CHNY/2024[2017-18]Status: DisposedITAT Chennai08 Apr 2025AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1857/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 Chiranjjeevi Wind Energy Limited, The Assistant Commissioner 26A, Kamaraj Road, Vs. Of Income Tax, Mahalingapuram, Corporate Circle -1, Pollachi, Coimbatore. Coimbatore – 642 002. Pan: Aaacc 8761H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri R. Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 03.04.2025 घोषणा क" तारीख/Date Of Pronouncement : 08.04.2025 आदेश /O R D E R Per S.R. Raghunatha: This Appeal Of The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi Dated 22.04.2024 For The Assessment Year 2017-18. 2. At The Outset, We Find That There Is A Delay Of 13 Days In Appeal Filed By The Assessee, For Which Petition For Condonation Of Delay Along With Reasons For Delay Has Been Filed. After Considering The Petition Filed By The Assessee & Also Hearing Both The Parties, We Find That There Is A Reasonable Cause For The Assessee In Not Filing Appeal On Or Before The Due Date Prescribed Under The Law & Thus, In The Interests Of Justice, We Condone Delay In Filing Of Appeal & Admit Appeal Filed By The Assessee For Adjudication.

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Ms. Anitha, Addl.CIT
Section 269SSection 271D

outset, we find that there is a delay of 13 days in appeal filed by the assessee, for which petition for condonation of delay along with reasons for delay has been filed. After considering the petition filed by the assessee and also hearing both the parties, we find that there

Shailesh Co Operative Housing Society Limited, Navi Mumbai vs. Assessing Officer, ITO Ward 28(3)(1), Mumbai, Vashi Navi Mumbai

In the result, the grounds of appeal raised by the assessee are allowed for

ITA 698/MUM/2025[2015-2016]Status: DisposedITAT Mumbai08 Apr 2025AY 2015-2016

Bench: Shri Pawan Singhshri Girish Agrawalshailesh Co Operative Housing Society Limited Plot No. 12, Sector, Sector 19A Nerul (East) Navi Mumbai, Maharashtra -400706. Pan No. Aaaas8609J ……………. Appellant Versus

For Appellant: Ms. Vidya Jayakumar, CA/ARFor Respondent: Shri Rajesh Meshram, Sr. DR
Section 154Section 254(1)Section 80P(2)(c)Section 80P(2)(d)

response was received on application under section 154, the assessee filed appeal before CIT(A) on 02.02.2024. The assessee also filed application for condonation of delay of 2804 days in filing first appeal. Such fact was clearly stated in Form 35. The application of assessee for condonation of delay ... considered the submissions of both the parties and have gone through the orders of lower authorities. Firstly, we are considering the plea of condonation of delay before CIT(A) in filing the appeal. We find that assessee has filed an affidavit of Jayesh Bhaskar Mhatre, Secretary of assessee society

Nisar Ahmed Khan, Mumbai vs. ACIT Circle 20(2), Mumbai

In the result, the grounds of appeal raised by the assessee are

ITA 606/MUM/2025[2017-18]Status: DisposedITAT Mumbai08 Apr 2025AY 2017-18

Bench: Shri Pawan Singhshri Girish Agrawal(Physical Hearing) बनाम Nisar Ahmed Khan Acit, Circle – 20(2) 1St Floor, Room No. 23, Bootwala Piramal Chamber, Chawl, Duncan Road, M.A. Road, Vs Lal Baug, Parel, Mumbai - 400008 Mumbai-400012 Pan No. Aiipa2008C अपीलाथ"/Appellant ""थ" /Respondent

Section 144Section 254(1)Section 69A

rival submissions of both the parties and have gone through the orders of lower authorities carefully. Firstly, we are considering the plea of condonation of delay of 455 days in filing the appeal before Tribunal. We find that ld. AR of the assessee has taken firm stand that the assessee ... that the assessee was not aware about the passing of impugned order by ld CIT(A), therefore, we find a reasonable cause for condoning the delay in filing appeal. Thus, delay of 455 days in filing appeal before Tribunal is condoned. Now, adverting the merits of the case

Sanjeev Kumar Tyagi, New Delhi vs. Assistant Commissioner of Income Tax, Circle-65(1), New Delhi

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 1263/DEL/2024[2013-14]Status: DisposedITAT Delhi08 Apr 2025AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumarassessment Year: 2015-16 Sangeeta Bansal, Vs. Pr. Commissioner Of Income 425, Jagriti Enclave, Tax, Central-3, Delhi-1100 92 New Delhi Pan No. Aaipb2360E (Appellant) (Respondent)

For Appellant: Ms. Shilpi Gupta, CA & Shri SheryFor Respondent: Shri Jitender Singh, SR. DR
Section 263Section 4

assessee. If such a prayer is made, the Registry shall entertain the prayer without insisting upon any application to be filed for condonation of delay in restoration of the appeal and on such request made by the assessee by filing a Miscellaneous Petition for Restoration, the Registry shall place such

M/S. Junior Chamber International, Ranchi vs. ITO, Exemption Ward, Ranchi

In the result, grounds of appeal raised by the appellant are allowed for statistical purposes only

ITA 33/RAN/2024[2015-16]Status: DisposedITAT Ranchi07 Apr 2025AY 2015-16

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 12A

that there is a delay of 36 days in filing this appeal before the Tribunal, for which the appellant has filed application for condonation of delay. In the condonation application, the learned Authorised Representative (ld. AR) of the appellant stated that the delay was caused due to the fact that ... entitled for any leniency at this stage. 4. We have considered the rival submissions of both the parties and perused the application for condonation of delay. In the application, the appellant stated that delay was caused due to the fact that the management of the society is changed each year

Shri Pratapbhai Hamirbhai Rathod, Village Dudana, Taluka Kodinar, Dist. Gir Somnath vs. The ITO Ward-1, Junagadh

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

ITA 880/RJT/2024[2017-18]Status: DisposedITAT Rajkot07 Apr 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 880 /Rjt/ 2024 ("नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Pratapbhai Hamirbhai Rathod The Ito, Ward-1, Junagadh Vs. 8, Karadiya Gyati Vistar, Village Ito, Bhootnath Chamber, Opp. Dudana Of Kodiar Taluka, Boudin Collage, Dist. Gir, Somnath - 362720 Junagadh-362001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Awypr7036H (Appellant) (Respondent) Appellant By : Shri Chetan Aggarwal, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 22/01/2025 Date Of Pronouncement : 07/04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

For Appellant: Shri Chetan Aggarwal, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 131Section 142(1)Section 144Section 250Section 253(5)Section 254Section 69A

delay of 354 days in filing the appeal. The Ld. AR of the assessee submitted that the assessee has filed an application for condonation of delay support by the affidavit, relevant para contain reasons for the delay, the same is reproduced. Your Petitioner, not so educated, is an agriculturist engaged ... Thus, taking into account the provision of section 253(5) and the decision of Hon’ble Supreme Court, we take a judicious view, condone the delay, and admit the appeal and proceed further for hearing. 5. Brief facts of the case that assessee during the demonetization period, the assessee

Shri Ramniklal Hirji Patel, Rajkot vs. The ITO Ward-2, Bhuj, Bhuj-Kutch

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

ITA 105/RJT/2024[2014-15]Status: DisposedITAT Rajkot07 Apr 2025AY 2014-15

Bench: Dr. Arjun Lal Saini

For Appellant: Written SubmissionFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 144Section 148Section 253(5)Section 50C

delay of 199 days in filing the appeal. The Ld. AR of the assessee submitted that the assessee has filed an application for condonation of delay support by the affidavit, relevant para contain reasons for the delay, the same is reproduced. “2.1. The assessee is senior citizen and suffering from ... Thus, taking into account the provision of section 253(5) and the decision of Hon’ble Supreme Court, we take a judicious view, condone the delay, and admit the appeal and proceed further for hearing. 5. Brief facts of the case are that the assessee is reopening notices

Rajesh Kumar Bhadani, Gaya vs. ITO, Ward- 3 (2), Gaya

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

ITA 704/PAT/2024[2017-18]Status: DisposedITAT Patna07 Apr 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 250Section 69Section 69A

Bhadani. 1.1. The Registry has informed that the appeal filed by the assessee is barred by limitation by 211 days. An application seeking condonation of delay has been filed by the assessee stating as under: “I am an Individual and deriving income from whole sale business of Onion Potato ... knowledge. I.T.A. No.: 704/PAT/2024 Assessment Year: 2017-18 Rajesh Kumar Bhadani. It is therefore requested that your honour would be kind enough to condoned the delay and hear the appeal on merits.” 1.2. Considering the application for condonation of delay and the reasons stated therein, we are satisfied that

Shree Rani Sati Textiles, Muzaffarpur vs. ACIT/DCIT, Cir-2, Muzaffarpur

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

ITA 701/PAT/2024[2016-17]Status: DisposedITAT Patna07 Apr 2025AY 2016-17

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 250Section 253(5)

Textiles. 1.1. The Registry has informed that the appeal filed by the assessee is barred by limitation by 135 days. An affidavit seeking condonation of delay has been filed by the assessee stating as under: “01. That the Deponent Mr. Raj Kumar Tulsyan is the managing partner of the firm ... counsel and drafting of grounds of appeal after gathering relevant information. For this deponent cannot be held responsible.” 1.2. Considering the affidavit for condonation of delay and the reasons stated therein, we are satisfied that the assessee had a reasonable and sufficient cause and was prevented from filing the instant

Satish Kumar Radheshyam Choudhari, Indore vs. Income Tax Officer, Indore

ITA 406/IND/2024[2013-14]Status: DisposedITAT Indore07 Apr 2025AY 2013-14

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshimember

Section 144Section 147Section 246ASection 249(2)Section 249(3)Section 250Section 253

delay in filing appeal due to delay at the end of the tax consultant. The relevant extract of the appellant with respect to condonation of delay is reproduced as under:- "The appellant was in process of fling the appeal within 30 days of the date of passing of order ... appeal was not fled at that time. It clearly shows that there was no mensrea from appellants end. Therefore, it is prayed to condone the delay and accept the said appeal.” 2.3 That in para 3.5 of the impugned order the Ld. CIT(A) has observed and avered as under

Mahipal, Gurgaon vs. Income Tax Officer, Ward 1 (2), Alwar

ITA 138/JPR/2025[2010-11]Status: DisposedITAT Jaipur07 Apr 2025AY 2010-11

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: NoneFor Respondent: Shri Anup Singh, Addl. CIT-DR
Section 144

could not be filed before Learned CIT(A) within prescribed period of limitation. 5. Learned CIT(A) while, dealing with the prayer for condonation of delay in filing the appeal, observed that there was no sufficient cause, which prevented the appellant from presenting appeal within the prescribed period of limitation ... Firstly, the applicant was required to establish the averments put forth while seeking condonation of delay. In this regard, the 3 Mahipal vs. ITO appellant should have submitted all the relevant documents. No such document has been submitted before us. At the same time, while dealing with said plea Learned

Dms Papers Private Limited, Patiala vs. CPC, Bengaluru

The appeal stand allowed for statistical purposes

ITA 741/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh07 Apr 2025AY 2021-22

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.741/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2021-22) Dms Papers Private Ltd. Cpc 7957/5, Ranbir Marg, Ist Floor बनाम/ Dukhniwaran Sahib-147001. Prestige Alpha No.48/148/2 Beratenaagarahara Begur, Vs. Hosurrd, Uttarahalli Hobli, Karnataka. 560100. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecd-3740-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : None ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 07-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 07-04-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Addl. / Joint Commissioner Of Income Tax (Appeals), Bengaluru [Cit(A)] Dated 30-04-2024 In The Matter Of An Intimation Issued By Cpc On 24-08-2022. The Assessee Opted For New Tax Regime U/S 115Baa(5) But It Failed To File Requisite Form 10-Ic To Lay

For Appellant: NoneFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 115BSection 119(2)(b)

adjournment application of Ld. AR, it emerges that the assessee has already preferred condonation application before appropriate authority u/s 119(2)(b) seeking condonation of delay in filing From 10-IC. The application is stated to be pending for decision. Considering this fact, we set aside the impugned order

Guru Nanak Trust for Charitable, Mohali vs. Income Tax Officer, Exemptions Ward, Chandigarh

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

ITA 1079/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh07 Apr 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Ms. Shruti Khandelwal, Advocate for Shri Parikshit Aggarwal, C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 144Section 249(3)Section 282

been mentioned. The appeal was dismissed by the Ld. CIT(A) mainly because no affidavit was provided by the assessee for the condonation of delay. However, technical issues should not outweigh fair justice if the appellant acted in good faith. We are of the opinion that in the interest

ACIT, Circle, Panchkula vs. M/S Haryana State Industrial & Infrastructure Dev. Corp. Ltd., Panchkula

In the result, appeal of the Revenue is dismissed

ITA 1424/CHANDI/2019[2014-15]Status: DisposedITAT Chandigarh07 Apr 2025AY 2014-15

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri A.K. Jindal and Ms. Rattan Kaur, C.A’sFor Respondent: Shri Rohit Sharma, CIT DR
Section 14ASection 28

under Section 253 of the Income Tax appropriate action lies in Act, 1961 without there being any application filing appeal before the for condonation of delay by the Assessee? Hon’ble High Court and the said ground cannot be decided within the limited domain of section

Ahmednagarzilha Parishad Servants Co-Op Credit Society Ltd, Ahilyanagar vs. ITO Ward 1, Ahilyanagar

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

ITA 2786/PUN/2024[2020-21]Status: DisposedITAT Pune07 Apr 2025AY 2020-21

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2020-21 Ahmednagar Zilha Parishad Servant’S Ito, Ward – 1, Co-Op Credit Society Ltd. Ahilyanagar Vs. Tilak Road, Opp. Wadia Park, Ahilyanagar – 414001 Pan: Aaaja0362K (Appellant) (Respondent) Assessee By : Shri Prasad S Bhandari (Virtual) Department By : Shri Ramnath P Murkunde Date Of Hearing : 01-04-2025 Date Of Pronouncement : 07-04-2025 O R D E R

For Appellant: Shri Prasad S Bhandari (Virtual)For Respondent: Shri Ramnath P Murkunde
Section 143(3)Section 270ASection 56Section 57Section 80PSection 80P(2)(a)

assessee submitted that the delay should be condoned. 2 3. We have heard the rival arguments of both sides on the issue of condonation of delay. We find the Hon'ble Supreme Court in the case of Collector, Land Acquisition vs. Mst. Katiji & Ors. (supra) has held that when substantial

Lions Nab Community Eyecare Centre Miraj, Miraj, Sangli vs. Exemption Ward-Kolhapur, Tarabai Park, Kolhapur

In the result, the appeal of the assessee is allowed

ITA 1245/PUN/2024[2017-18]Status: DisposedITAT Pune07 Apr 2025AY 2017-18

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1245/Pun/2024 Assessment Year : 2017-18 Lions Nab Community Vs. Cit(Exemption), Eyecare Centre Miraj, Kolhapur Plot No. P-39, Midc, Miraj, Sangli-416410 Pan : Aabfl4373L Appellant Respondent

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Sandeep P. Sathe
Section 271F

dismissed the appeal in limine on account of delay in filing of the appeal and thus prayed for condonation of delay. So far as the merits of the case is concerned, the same relates to levy of penalty u/s. 271F of the Act at Rs.5,000/- for not filing

Employees Provident Fund Organisation Staff Co-Op Credit Society Ltd, Hyderabad vs. ITO., Ward-4(1), Hyderabad

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

ITA 1366/HYD/2024[2017-18]Status: DisposedITAT Hyderabad07 Apr 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Madhusudan Sawdia, Hon’Bleassessment Year: 2017-18 Employees Provident Fund Vs. Income Tax Officer, Ward –4(1), Organisation Staff Hyderabad. Co-Op Society Ltd., Barkatpura, Hyderabad. Pan : Aaaae1453C (Appellant) (Respondent) Assessee By: Shri S. Rama Rao, Advocate. Revenue By: Dr. Sachin Kumar, Sr.A.R. Date Of Hearing: 02/04/2025 Date Of Pronouncement: 07/04/2025

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Dr. Sachin Kumar, Sr.A.R
Section 143(3)Section 80P

Mumbai is erroneous both on facts and in law. 2) The learned JCIT erred in not allowing the petition for condonation of delay of 37 days in filing the appeal; 3) The learned JCIT ought to have considered the reasons for delay in filing the appeal and ought to have ... condoned the delay in filing the appeal: 4) The learned JCIT ought to have decided the appeal on merits without disposing the appeal in limini; 5) The order of the learned JCIT is erroneous in not considering the grounds of appeal and in not holding that the appellant is eligible

Pranita Das, Bangalore vs. ACIT, Circle-3(3)(1), Bangalore

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

ITA 42/BANG/2025[2019-20]Status: DisposedITAT Bangalore07 Apr 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Narendra Kuman Jain, AdvocateFor Respondent: Shri Subramanian S, JCIT (DR)
Section 139Section 90

income tax Appellate Tribunal of different benches. However, the ld. CIT(A) also noted that the assessee had already submitted an application for condonation of delay in filing Form 67 before the ld. Principal Commissioner of Income Tax (PCIT) on November 15, 2021, which was still pending at that time

Pranita Das, Bangalore vs. ACIT, Circle-3(3)(1), Bangalore

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

ITA 41/BANG/2025[2018-19]Status: DisposedITAT Bangalore07 Apr 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Narendra Kuman Jain, AdvocateFor Respondent: Shri Subramanian S, JCIT (DR)
Section 139Section 90

income tax Appellate Tribunal of different benches. However, the ld. CIT(A) also noted that the assessee had already submitted an application for condonation of delay in filing Form 67 before the ld. Principal Commissioner of Income Tax (PCIT) on November 15, 2021, which was still pending at that time

The Sajjan Jain Support Trust, Kandivali (East) vs. Income Tax Officer, Ward 41(4)(4), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 1206/MUM/2025[NOT APPLICABLE]Status: DisposedITAT Mumbai07 Apr 2025

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjeethe Sajjan Jain Support Trust Vs Income Tax Officer, Ward 41(4)(4), 499/2, A Arkade House, Ashok Kautilya Bhavan, Bandra Kurla Nagar, Near Children Complex, Bandra (E), Mumbai-400 Academy, Kandivali (East), 051 Mumbai-400 010 Pan : Aadtt2208C Appellant Respondent

For Appellant: Shri Rushabh Mehta (virtual)For Respondent: Ms. Rmapriya Raghavan - CIT DR
Section 12ASection 12A(1)(ac)Section 80G(5)

Subsequently, the email address was updated, and the official email was registered on the online portal. The Ld.DR raised an objection to the condonation of delay. However, we find no merit in the DR’s argument. Considering the facts of the case, we accept the affidavit submitted by the assessee ... condone the delay of 478 days. Accordingly, the appeal is admitted for adjudication. 4. The Ld.AR placed that the assessee was granted provisional registration in Form 10AC under section 12A(1)(ac)(iv) and under section 80G(5) of the Act on 24/05/2022 and 22/06/2022. Subsequently, the assessee had filed