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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

Amrut Public Charitable Trust, Mumbai vs. ITO, Exemption Ward 1(1), Mumbai

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

ITA 7387/MUM/2025[2026-27]Status: DisposedITAT Mumbai19 Jan 2026AY 2026-27

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokaramrut Public Charitable Ito Exemption Trust Ward 1(1), Block 4, Plot No. 578A, Vs. Cumballa Hill, Jitendra Bldg, Pedder Road, Jamejamshed Road, Mumbai-400 026 Matunga, Mumbai- 400 019 Pan/Gir No.Aaata4810A (Applicant) (Respondent) Assessee By Shri P. P. Jayaraman, Ld. Ar Revenue By Shri Rajesh Kumar Yadav, Ld. Dr Date Of Hearing 13.01.2026 Date Of Pronouncement 19.01.2026

Section 12ASection 80G(5)

mistakenly presumed to be co-terminus with the registration under section 12A, i.e. up to A.Y. 2026–27. The assessee also sought condonation of delay. 4. The learned CIT(Exemptions), after examining the submissions, held that as per clause (iii) of the first proviso to section 80G(5), an institution ... misunderstood by the appellant that provisional approval u/s 80G(5) is also valid till AY 2026-27. The appellant prays for the condonation of delay under the principle of ‘sufficient cause’, as the oversight was technical and no male fide intent to circumvent the law existed. 3. That the learned

Sunder Nagar Satsang Sabha, Mumbai vs. CIT(Exemption), Mumbai

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

ITA 7234/MUM/2025[N.A ]Status: DisposedITAT Mumbai19 Jan 2026

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

Section 12ASection 12A(1)Section 12A(1)(ac)

assumption that, the provisional registration was valid till 31/03/2026. Assessee thus submitted that, the lapse was unintentional and prayed for condonation of delay in the interest of justice and public welfare. 2.2. The Ld.CIT(E), after considering the submissions advanced, rejected the application for regularization of the provisional registration ... filing of the application within the due date. In absence of a reasonable cause of delay the request of the applicant for condonation of delay is not acceptable. 5. Since registration under section 12AB is to be granted in terms of the provisions of section 12AB

Mahesh Pyarelal Sharma, Mumbai vs. Asst Comm of Income Tax Circle 34(2), Mumbai

ITA 7218/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Jan 2026AY 2015-16

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: NoneFor Respondent: Shri Umashankar Prasad
Section 143(3)Section 147

Learned Departmental Representative and have perused the material on record including the grounds raised by the Assessee in the present appeal, application seeking condonation of delay alongwith the accompanying affidavit and the orders passed by the authorities ITA No.7178, 7217&7218/Mum/2025 Assessment Year 2012-2013, 2013-2014 & 2015-2016 below ... Assessment Year 2012-2013. 4. The registry has marked delay of 494 days in filing the present appeal. In the application seeking condonation of delay the Assessee has requested that the delay in filing the present appeal be condoned and has provided the following explanation which is supported

Mahesh Pyarelal Sharma, Mumbai vs. Asst Comm of Income Tax Circle 34(2), Bandra Kurla Complex

ITA 7217/MUM/2025[2013-14]Status: DisposedITAT Mumbai19 Jan 2026AY 2013-14

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: NoneFor Respondent: Shri Umashankar Prasad
Section 143(3)Section 147

Learned Departmental Representative and have perused the material on record including the grounds raised by the Assessee in the present appeal, application seeking condonation of delay alongwith the accompanying affidavit and the orders passed by the authorities ITA No.7178, 7217&7218/Mum/2025 Assessment Year 2012-2013, 2013-2014 & 2015-2016 below ... Assessment Year 2012-2013. 4. The registry has marked delay of 494 days in filing the present appeal. In the application seeking condonation of delay the Assessee has requested that the delay in filing the present appeal be condoned and has provided the following explanation which is supported

Mahesh Pyarelal Sharma, Juhu Andheri West vs. Income Tax Officer Circle 34(2), Mumbai

ITA 7178/MUM/2025[2012-13]Status: DisposedITAT Mumbai19 Jan 2026AY 2012-13

Bench: notices for assessment were received and had commenced treatment for the same. 5. That I was employed out of Mumbai and had to travel to Mumbai for short visit to take her to hospital for treatment and hence was unable to attend to the notices and income details during the assessment proceedings. Further, I was also mentally disturbed, leading to additions being made in the assessment. 6. That I had filed submissions before the Ld CIT(A) on to 10/04/2019. 7. That I had filed all submissions

For Appellant: NoneFor Respondent: Shri Umashankar Prasad
Section 143(3)Section 147

Learned Departmental Representative and have perused the material on record including the grounds raised by the Assessee in the present appeal, application seeking condonation of delay alongwith the accompanying affidavit and the orders passed by the authorities ITA No.7178, 7217&7218/Mum/2025 Assessment Year 2012-2013, 2013-2014 & 2015-2016 below ... Assessment Year 2012-2013. 4. The registry has marked delay of 494 days in filing the present appeal. In the application seeking condonation of delay the Assessee has requested that the delay in filing the present appeal be condoned and has provided the following explanation which is supported

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

there is delay of 265 days in filing the present appeal before this Tribunal. The Ld.AR in support has furnished an application seeking condonation of delay alongwith affidavit of the trustee of assessee that states as under:- ***This space is left blank intentionally, P.T.O.*** 3 I.T.A. No. 6764/Mum/2025 4 I.T.A ... Nothing to establish any such intention has been filed by the revenue before this Tribunal. In our opinion there was sufficient cause for condoning the delay as observed by Hon’ble Supreme Court in case of Collector Land Acquisition Vs. Mst. Katiji & Ors., reported

ACIT-6(1)(1), Mumbai vs. M/S Essar Power Gujarat Limited, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 4353/MUM/2025[2009]Status: DisposedITAT Mumbai19 Jan 2026

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 147Section 254

objections were filed only on 19.02.2025,thus, there is delay of 29 days in filing the CO. The assessee has filed application for condonation of delay in filing CO. The application for condonation of delay is supported by affidavit of Sumeet Agrawal, Joint General Manager (Taxation). The learned authorised With ... submits that relevant medical prescription and medical diagnosis and discharge slip are filed on record. The ld AR of the assessee prayed for condonation of delay in filing his CO. 4. On the other hand, the learned Commissioner of Income Tax- Departmental representative (Ld. CIT-DR) for the Revenue after

ACIT-6(1)(1), Mumbai vs. M/S Essar Power Gujarat Limited, Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 4352/MUM/2025[2012]Status: DisposedITAT Mumbai19 Jan 2026

Bench: Shri Pawan Singh & Shri Girish Agrawal

Section 147Section 254

objections were filed only on 19.02.2025,thus, there is delay of 29 days in filing the CO. The assessee has filed application for condonation of delay in filing CO. The application for condonation of delay is supported by affidavit of Sumeet Agrawal, Joint General Manager (Taxation). The learned authorised With ... submits that relevant medical prescription and medical diagnosis and discharge slip are filed on record. The ld AR of the assessee prayed for condonation of delay in filing his CO. 4. On the other hand, the learned Commissioner of Income Tax- Departmental representative (Ld. CIT-DR) for the Revenue after

Maharashtra Corporation Limited, Mumbai vs. Income Tax Officer Ward 4(2)(1), Mumbai

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

ITA 4146/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar

Section 131Section 143(1)Section 144BSection 147Section 148Section 69C

hereinafter referred to as “the Act”] as per his order dated 29.03.2022 passed under section 147 read with section 144B of the Act. Condonation of Delay 2. At the outset, we note that there is a delay of 169 days in filing the present appeal before the Tribunal, as pointed ... Registry. The assessee has filed an affidavit for condonation of delay, duly sworn by the Director of the assessee company, explaining the reasons for the said delay. On perusal of the affidavit, it is stated that the delay occurred on account of the assessee seeking appropriate legal advice and, more

M/S. Nanshi Export Private Limited, Mumbai vs. Income Tax Officer -15(2)(1), Mumbai

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

ITA 4099/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Om Prakash Kant () & Ms Kavitha Rajagopal () Assessment Year: 2017-18 Nanshi Export Private Limited Income Tax Officer-15(2)(1), 301, 3Rd Floor Stanford Plaza Opp. Mumbai Vs. Citi Mall Nr. Oberoi Spring New Link Aayakar Bhawan, Mumbai- Road, Andheri West, Maharashtra 400020 Pan No. Aadcn 0694 B Appellant Respondent

For Appellant: NoneFor Respondent: Ms. Beena Santosh, CIT DR
Section 144Section 148Section 69C

filing the present appeal. The assessee has filed an application in filing the present appeal. The assessee has filed an application for condonation of delay along with an for condonation of delay along with an affidavit sworn by its affidavit sworn by its director. In the affidavit, it has been

Jignesh Narendrabhai Mandaliya, Rajkot vs. The Income Tax Officer, Ward 2(1)(1), Rajkot

In the result, ground raised by the assessee is allowed for statistical purposes

ITA 874/RJT/2025[2019-20]Status: DisposedITAT Rajkot16 Jan 2026AY 2019-20

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Brijesh Parekh, ARFor Respondent: Shri Gopi Nath Chaubey, Sr. DR
Section 115BSection 147Section 250

appeal filed by the assessee, before the Tribunal, is barred by limitation by 104 days. The assessee moved a petition (an affidavit) for condonation of delay, requesting the Bench to condone the delay. The Learned Counsel for the assessee, explained the reasons for delay stating that Ld. Commissioner of Income ... 874/Rjt/2025 A.Y 19-20 Jignesh N Mandaliya 4. However, Ld. Senior DR for the Revenue opposed the prayer of assessee for condonation of delay and stated that assessee has failed to explain sufficient cause, therefore, delay should not be condoned. 5. I have heard both the parties on this preliminary

Shree Pindara Seva Sahkari Mandali Limited, Devbhumi Dwarka vs. Income Tax Officer (W), Dwarka

In the result, the appeal of the assessee, is allowed for statical purpose

ITA 404/RJT/2025[2018-19]Status: DisposedITAT Rajkot16 Jan 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.404/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2018-19 Shree Pindara Seva Sahkari Mandali Income Tax Officer, Wd-1, बनाम Ltd. At Pindara, Taluka Kalyanpur, Dwarka-361335 Devbhumi Dwarka (Guj) -361315 Vs. Pan No. : Aajas7145N (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Shreyash Sheth, Ld. Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाई क" तार"ख /Date Of Hearing : 17/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 16/01/2026 Order Per, Dr. Dinesh Mohan Sinha, Jm:

For Appellant: Shri Shreyash Sheth, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld.Sr.DR
Section 144Section 249(2)Section 249(3)Section 5

filing the appeal for 74 days, before Ld. CIT(A). The assessee filed the petition Sh. Pindara Seva Sahkari Mandali Ltd. for condonation of delay before the Ld. CIT(A) and explained the cause for the delay, however, despite of this, the ld. CIT(A) did not condone the delay ... given in the impugned order of Id. CIT(A). We find that during the appellate proceedings, the assessee submitted the following reasons, for condonation of delay: "On the facts and circumstances of the case, and in view of the position of law applicable on the given facts, I am satisfied

Samman Foundation, Gujrat vs. CIT(Exemption), Patna

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

ITA 545/PAT/2025[2024-25]Status: DisposedITAT Patna16 Jan 2026AY 2024-25

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am आयकर अपील सं./Ita Nos.544 & 545/Pat/2025 (ननिाारण वर्ा / Assessment Year :2024-2025) Samman Foundation, Vs. Cit(Exemption), Patna Ravi 203, Sauram Apartments, Opp. Vasna Bus Stop, Vasna Ahmedabad, Gujarat-380007 स्थायी लेखा सं./Pan No. : Aakcs 7166 C (अपीलाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri D.V.Pathi, ARFor Respondent: Md. A.H.Chowdhary, CIT-DR
Section 12ASection 12A(1)(ac)Section 80G

that both the appeals of the assessee are filed by 03 days each. In this regard, the assessee has filed an application for condonation of delay stating sufficient reasons for delay in filing both the appeals before the Tribunal, which are found reasonable. Ld. CIT-DR also did not raise ... serious objection to condone the delay. Accordingly, the delay of 03 days each in filing both the appeals before the Tribunal is condoned and both appeals of the assessee are admitted for hearing. 3. It was submitted by the ld. AR that the ld. CIT(E) has rejected/cancelled the application

Samman Foudation, Gujrat vs. CIT(Exemption), Patna

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

ITA 544/PAT/2025[2024-25]Status: DisposedITAT Patna16 Jan 2026AY 2024-25

Bench: Shri George Mathan, Jm & Shri Rajesh Kumar, Am आयकर अपील सं./Ita Nos.544 & 545/Pat/2025 (ननिाारण वर्ा / Assessment Year :2024-2025) Samman Foundation, Vs. Cit(Exemption), Patna Ravi 203, Sauram Apartments, Opp. Vasna Bus Stop, Vasna Ahmedabad, Gujarat-380007 स्थायी लेखा सं./Pan No. : Aakcs 7166 C (अपीलाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri D.V.Pathi, ARFor Respondent: Md. A.H.Chowdhary, CIT-DR
Section 12ASection 12A(1)(ac)Section 80G

that both the appeals of the assessee are filed by 03 days each. In this regard, the assessee has filed an application for condonation of delay stating sufficient reasons for delay in filing both the appeals before the Tribunal, which are found reasonable. Ld. CIT-DR also did not raise ... serious objection to condone the delay. Accordingly, the delay of 03 days each in filing both the appeals before the Tribunal is condoned and both appeals of the assessee are admitted for hearing. 3. It was submitted by the ld. AR that the ld. CIT(E) has rejected/cancelled the application

Lal Babu Prasad, Siwan vs. ACIT, Circle-2, Muzaffarpur

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

ITA 317/PAT/2025[2015-16]Status: DisposedITAT Patna16 Jan 2026AY 2015-16

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 133ASection 250Section 43B

that there is a delay of 437 days in filing the present appeal. In this connection, the assessee has filed an application seeking condonation of delay. After considering the reasons stated therein and being satisfied that the delay occurred due to sufficient cause, the delay of 437 days is condoned

Chanchal Kumar, Patna vs. ITO, Ward- 6 (4), Patna

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

ITA 241/PAT/2025[2016-17]Status: DisposedITAT Patna16 Jan 2026AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Sonjoy Sarmai.T.A. No.241/Pat/2025 Assessment Year: 2016-17 Chanchal Kumar……………………………… …………………....Appellant S/O Sharma Nand Singh, Chak Musallahpur, Chai Tola Gali, Near Cooperative Bank, Mahendru, Patna, Bihar- 800006.. [Pan: Cenpk3190J] Vs. Ito, Ward-6(4), Patna…….…..……………..………………….…..... Respondent Appearances By: Shri Vishal Kr. Adv. Appeared On Behalf Of The Appellant. Shri Manab Advak, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 13, 2026 Date Of Pronouncing The Order : January 16, 2026 आदेश / Order Per Sonjoy Sarma: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 30.07.2023 Passed By The Cit(A)-3, Patna U/S 250 Of The Income Tax Act, 1961 (The ‘Act’) For The Assessment Year 2016-17. 2. Brief Facts Of The Case Are That The Assessee Did Not File Its Return Of Income For The Assessment Year Under Consideration & The Case Was Reopened U/S 147. The Assessing Officer Completed Assessment U/S 143 R.W.S. 147 Of The Act By Making Addition Of Rs.81,66,750/- On Account Of Long Term Capital Gain.

Section 143Section 147Section 250

assessee has now preferred an appeal before the Tribunal with a delay of 590 days. The assessee filed an application for condonation of delay, explaining the reasons for such delay. After considering the submissions and the reasons stated, we are satisfied that there existed a reasonable cause preventing the assessee

Radhakishan, Khategaon, Dewas vs. ITO-2, Dewas

Appeals are allowed for statistical purpose

ITA 678/IND/2025[2010-11]Status: DisposedITAT Indore16 Jan 2026AY 2010-11
Section 144Section 147Section 148Section 246A

aside. It was next contended that the registry has pointed out the delay of 586 days in filing the instant second appeal. A condonation of delay application is placed on record of this Tribunal which reads as under:- Radhakishan ITA No. 678/Ind/2025 - A.Y.2010-11 Date: From: PAN: 05-08-2025 Radhakishan ... CLOPR1955C Radhakishan ITA No. 678/Ind/2025 - A.Y.2010-11 To, The Hon'ble Members, Income Tax Appellate Tribunal, Indore COP cep Sub: Application for condonation of delay in filing appeal under Section 253(5) of the Income-tax Act, 1961 – A.Υ. 2010-11 - Reg. Hon'ble Sir, The Appellant respectfully submits

Kalpana Narware, Betul vs. Income Tax Officer, Betul

Appeal is allowed for statistical purpose

ITA 202/IND/2025[2017-18]Status: DisposedITAT Indore16 Jan 2026AY 2017-18

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi**

Section 144Section 253

placed before bench the copies of medical reports. In view of this situation, Ld. DR for revenue does not have any objection against condonation of delay. We find that the assessee has explained "sufficient cause" for occurrence of delay, accordingly the delay is condoned taking into account the facts ... appeal on the ground of time-barred. Ld. AR submitted that the assessee has filed following "Interlocutory Application" before this bench seeking condonation of delay in filing firstappeal duly supported by an affidavit: ![](_page_2_Figure_1.jpeg) EFORE THE HON'BLE INCOME TAX APPELLATE TRIBUNAL BENCH AT INDORE ITA 202/IND/2025

Neha Tamrakar, Bhopal vs. Income Tax Officer 5 (1), Bhopal

In the result, the “Impugned Order” is set aside as & by

ITA 175/IND/2025[2009-10]Status: DisposedITAT Indore16 Jan 2026AY 2009-10

Bench: Shri B.M. Biyani & Shri Paresh M Joshineha Tamrakar, Ito -5(1), बनाम/ 177 A Sector, Indrapuri Bhopal. Vs. Bhopal(M.P.) (Pan: Ajtpt6475G) (Appellant) (Respondent) Assessee By Shri Soumya Bumb, Ca Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 12.01.2026 Date Of Pronouncement 16.01.2026 आदेश/ O R D E R

Section 129Section 139Section 142(1)Section 144Section 147Section 148Section 148(2)Section 151Section 246Section 250

registry has pointed out the delay of 409 days in filling the instant second appeal. It was submitted that in this regard a condonation of delay Page 8 of 13 Neha Tamrakar ITA No. 175/Ind/2025 - A.Y.2009-10 application is made together with an affidavit dated 10.01.2026. It was submitted that impugned ... malafide intention of the assessee. Assessee has shown Page 9 of 13 Neha Tamrakar ITA No. 175/Ind/2025 - A.Y.2009-10 sufficient cause. Accordingly we condone the delay & admit the appeal. 3.2 The Ld. AR for the assessee then contended that the “Impugned Assessment Order” is exparte. Non compliances have happened. The jurisdiction

Kuvargiri Hiragiri Gosai, Junagadh vs. The ITO, Ward-1(2), Bhavnagar

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

ITA 2120/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamblekuvar Giri Hiragiri Gosai The Income Tax Vs. Panch Dash Nam Juna Akhada Officer, Thana Pati Kuvar Bharthi Ward-1 (2), Guru Shri Indra Bharthi Bhavnagar – 364 002 Junagadh – 362 001

For Appellant: Shri P.B. Parmar, ARFor Respondent: -None-
Section 147Section 148Section 234ASection 271(1)(b)Section 271(1)(c)Section 271FSection 69A

penalty proceedings under section 271F of the Act.” 3. The appeal is delayed by 72 days. An Affidavit dated 08/01/2026 in support of condonation of delay has been filed. wherein, it has been deposed by the assessee that his Tax Consultant had assigned the task of preparing and filling ... time due to Diwali vacation. Non-filing of the appeal was on account of reasons behind assessee’s control and prayed to condone the delay and the appeal may be decided on merits. Looking to the facts and circumstances of the case, we condone the delay. 4. The brief facts