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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

Alang Steel Recycling Private Limited, Bhavnagar vs. The Pr. CIT-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1605/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Pr. Cit-1, Private Limited Vs. Ahmedabad – 380 015 Ground Floor, Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri R.P. Rastogi, Cit-Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

Section 263Section 37Section 69C

change all or any of the grounds of appeal at the time of or before the hearing of the appeal.” Application for condonation of delay: 3. At the outset, we note that the assessee has filed an application seeking condonation of delay of 83 days in filing the present appeal ... appeal within the prescribed time. It is a settled principle that a liberal approach is to be adopted while considering applications for condonation of delay so as to advance substantial justice rather than to defeat it on technical grounds. 5.1. Accordingly, in the interest of justice, the delay

Alang Steel Recycling Private Limited, Bhavnagar vs. The Dy.CIT, Circle-1, Bhavnagar

The appeal of the assessee is allowed for statistical purposes

ITA 1604/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Dy. Cit-1, Private Limited Vs. Circle-1, Ground Floor, Bhavnagar – 364 001 Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri Abhijit, Sr.Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

Section 147Section 234ASection 270ASection 37

grounds of appeal at the time of or before the hearing of the appeal. 3. The assessee has filed application for condonation of delay of 114 days in filing of the present appeal. We have considered the application filed by the assessee seeking condonation of delay of 114 days ... suggest that the delay was deliberate or intentional. It is well settled that a liberal approach should be adopted while considering applications for condonation of delay so as to advance substantial justice, particularly when sufficient cause is shown. In the present case, we are satisfied that the assessee was prevented

Kanubhai Maganbhai Patel, Anand vs. ITO, Ward-1(3)(1), Petlad

In the result, the appeal of the assessee is allowed

ITA 1404/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2012-13

Bench: Ms. Suchitra Kambleassessment Year 2012-13

For Appellant: Shri Parin Shah, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 148Section 234ASection 271(1)(c)Section 69A

therefore was not aware of details of notice and the filing of second appeal. The ld. A.R. has given the detailed explanation for condonation of delay, hence the delay is condoned. I.T.A No. 1404/Ahd/2025 Kanubhai Maganbhai Patel, A.Y. 2012-13 6. The ld. A.R. submitted that the assessee has given

Balaji Finance, Gawal vs. Income Tax Officer, Ward-1, Mahbubnagar

ITA 1375/HYD/2025[2022-23]Status: DisposedITAT Hyderabad16 Jan 2026AY 2022-23

delay of 89 days in filing the present appeal before this Tribunal, for which the assessee has filed a petition seeking condonation of delay along with an affidavit explaining the reasons for such delay. The Learned Authorised Representative (“Ld. AR") submitted that the order ... Singh vs. The State of Madhya Pradesh, Special Leave Petition (Civil) No. 6145 of 2024, dated 21.03.2025, in support of the prayer for condonation of delay. Accordingly, the Ld. AR prayed for condonation of the delay and admission of the appeal for adjudication on merits. Per contra, the Learned Departmental

Veenus Jewellars, Warangal vs. Income Tax Officer, Ward-1, Warangal

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

ITA 1373/HYD/2025[2017-18]Status: DisposedITAT Hyderabad16 Jan 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri K.A. Sai Prasad, C.AFor Respondent: Shri Madhukar AVES, Sr. DR

delay of 181 days in filing the present appeal before this Tribunal, for which the assessee has filed a petition seeking condonation of delay along with an affidavit explaining the reasons for such delay. The Learned Authorised Representative (“Ld. AR”) submitted that while filing Form No. 35, the assessee ... part of the assessee, but occurred due to reasons beyond the control of the assessee. Accordingly, the Ld. AR prayed for condonation of delay and admission of the appeal for adjudication on merits. 3. Per contra, the Learned Departmental Representative (“Ld. DR”) submitted that the Ld. CIT(A) had issued

Basudebpur Uttarbarh Samabay Krishi Unnayan Samity Ltd., Purba Medinipur vs. A.C.I.T., Cir - 27(2) Now Cir - 27(1), Haldia

In the result the appeal of the assessee stands allowed

ITA 1850/KOL/2025[2015-2016]Status: DisposedITAT Kolkata16 Jan 2026AY 2015-2016

Bench: SHRI GEORGE MATHAN (Judicial Member)

For Appellant: Shri Soumitra Choudhary, ARFor Respondent: Shri Abhijit Adhikary, Sr. DR
Section 80P

appeal of the assessee is filed belatedly by 323 days. In this regard, the assessee has filed an application for condonation of delay supported with an affidavit stating therein sufficient reasons for condonation of delay. Ld.Sr. DR has also not objected to condone the delay. Considering the prayer ... assessee in the application and the sufficient reasons for delay, I condone the delay of 323 days in filing the appeal and the appeal of the assessee is admitted for hearing. 3. It was submitted by the ld. AR that the only issue in the assesse’s appeal is regard

B. Das Memorial Medical Complex, Tarakeswar vs. ACIT, Circle 23(1), Hooghly

In the result, appeal of the assessee is partly allowed for statistical purposes and the stay application stands dismissed

ITA 1727/KOL/2025[2022-2023]Status: DisposedITAT Kolkata16 Jan 2026AY 2022-2023

Bench: Shri George Mathan & Shri Rajesh Kumarstay Application No.01/Kol/2026 (Arising Out Of Ita No.1727/Kol/2025) (निर्धारण वर्ा / Assessment Year : 2022-2023) B.Das Memorial Medical Vs Acit, Circle-23(1), Hooghly Complex, C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Aaxfb 8400 A (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri Somnath Ghosh, Advocate रधजस्व की ओर से /Revenue By : Shri S.B.Chakraborty, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 16.01.2026 घोषणा की तारीख/Date Of Pronouncement : 16.01.2026 आदेश / O R D E R Per Bench : This Stay Application Is Filed By The Assessee Seeking Stay Of Outstanding Demand Of Rs.1,63,12,293/- Arising Out Of The Ita No.1727/Kol/2025. 2. It Was Noticed That The Assessment Order Is An Ex-Parte Order & It Is Also Noticed That The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee On Account Of Non-Condonation Of Delay. It Was Informed To Both The Sides That The Appeal Can Be Disposed Off. 3. It Was Fairly Agreed By Both The Sides That The Delay In Filing Of The Appeal Before Ld. Cit(A) May Kindly Be Condoned & The Issue May Be Restored To The File Of Ld. Jurisdictional Assessing Officer For Readjudication.

For Appellant: Shri Somnath Ghosh, AdvocateFor Respondent: Shri S.B.Chakraborty, Sr. DR

parte order and it is also noticed that the ld. CIT(A) has dismissed the appeal of the assessee on account of non-condonation of delay. It was informed to both the sides that the appeal can be disposed off. 3. It was fairly agreed by both the sides that

Deputy Commissioner of Income Tax, Central Circle-20, Delhi, Jhadewalan vs. Asian Hotels (North) Limited, Delhi

In the result, appeal of the Revenue in ITA No

ITA 3729/DEL/2025[2016-17]Status: DisposedITAT Delhi16 Jan 2026AY 2016-17

Bench: Shri Yogesh Kumar Us & Shri Naveen Chandra

For Appellant: Ms. Sunidhi, AdvFor Respondent: Shri Sumer Singh Meena, CIT- DR
Section 143Section 143(3)Section 263Section 43BSection 69C

pass a fresh order in pursuance to upheld order u/s 263 of the Act? 3. The Revenue has filed an application for condonation of delay on the ground that the authorization to file appeal before the ITAT was received late. Having perused the application for condonation of delay, we find ... that there is sufficient cause for filing the appeal belatedly by 35 days. We, therefore, condone the delay. 4. Briefly stated, the facts of the case are that the assessee is a limited company which filed its return of Income for A.Y 2016-17 on 29.09.2016 declaring loss

Horizon Hge Electronic Equipment India Pvt Ltd, Gautam Buddha Nagar vs. DCIT, Circle-10(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 2695/DEL/2025[2020-21]Status: DisposedITAT Delhi16 Jan 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2020-21] Horizon Hge Electronicequipment Vs Dcit India Pvt.Ltd., 1St Floor, Awho, Circle-10(1) Sector-29, Noida Sector-37, S.O- New Delhi Gautam Budh Nagar, Uttar Pradesh-201303. Pan-Aacch0704R Appellant Respondent Assessee By Shri Satyen Sethi, Adv. & Shri A.T.Panda, Adv. Revenue By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 19.11.2025 Date Of Pronouncement 16.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 05.03.2025 By Ld. Commissioner Of Income Tax (A)/Addl/Jcit(A)-5, Kolkata [“Ld. Cit(A)”] In Appeal No. Addl/Jcit(A)-5 Kolkata/10001/2019-20 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Intimation Order Dated 18.12.2021 Passed U/S 143(1) Of The Act Pertaining To Assessment Year 2020-21. 2. Brief Facts Of The Case Are That The Assessee Is A Company, Derived Income From Business & Filed Its Return Of Income On 14.10.2020, Declaring Total Income Of Inr 2,42,00,780/- & Paid Taxes In Terms Of The Concessional Rate Of Tax Provide U/S 115Baa Which Was Denied By Cpc In The Intimation Order Passed U/S 143(1) Of The Act For The Reason That Form 10-Ic Was Filed Delayed.

Section 115BSection 143(1)Section 250

Appellant was not entitled to be taxed under section 115BAA of the Act because the Appellant did not appear to have applied for condonation of delay to the CCIT. 3. The learned Addl/JCIT (A) erred on facts and in law in not taking notice of several judicial precedents cited

Late Shri Duleechanda Through Legal Representative Shri Rajendra Chaudhary, Gautam Budh Nagar vs. ITO, Ward- 1(2), Ghaziabad

In the result, appeal of assessee in ITA No

ITA 1353/DEL/2025[2010-11]Status: DisposedITAT Delhi16 Jan 2026AY 2010-11

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: Shri Sahil Sharma, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 120Section 144Section 147Section 151Section 250

NFAC, Delhi dated 04.12.2024 pertaining to A.Y 2010-11. 2. The ld. counsel for the assessee has filed an application for condonation of delay. Having perused the condonation petition, we find [A.Y 2010-11] Shri Duleechanda Vs. ITO that the reason for delay in filing the appeal ... affidavit alongwith medical certificates, to be plausible. Hence the assessee has sufficient cause for not filing the appeal in time. Accordingly, we condone the delay and admit the appeal. 3. The grounds raised by the assessee read as under: “1. That on the facts and circumstances of the case

Income Tax Officer, Exemption vs. Dogra Educational Society, Ground Floor

The appeal of the revenue is dismissed

ITA 4569/DEL/2024[2018-19]Status: DisposedITAT Delhi16 Jan 2026AY 2018-19

Bench: Shri Anubhav Sharma & Shri Manish Agarwalincome Tax Officer, Vs. Dogra Educational Society Exemption, Ward-1(3), Ground Floor, 416 Bhera Room No.2419, 24Th Floor, Enclave, Pachim Vihar E-2 Floor, Civic Centre Delhi – 110058 Delhi – 110001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaatd4135D Appellant .. Respondent

For Appellant: NoneFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr
Section 11Section 119(2)(b)Section 12ASection 12A(1)Section 139Section 139(4)Section 143(3)

Audit report in Form 10B has not been filed along with the return of income, the assessee was required to file application of condonation of delay u/s 119(2) of the Act before the CIT. (Exemption) in accordance with the CBDT Circular No. 02/2020.However as per the information available ... such application for condonation of delay u/s 119(2) of the Act has been filed before the P a g e | 7 Dogra Educational Society(AY: 2018-19) CIT (Exemption), New Delhi. Hence as per the CBDT Circular No. 02/2020 dated 3rdJanuary, 2020, the assessee is not eligible for claiming

Johar Gadly Alias Zohar Mohammad Bhai Through Legal Heir Rashida Gadly, Patna vs. ACIT, Circle-2, Patna

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

ITA 295/PAT/2025[2017-18]Status: DisposedITAT Patna15 Jan 2026AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.295/Pat/2025 Assessment Year: 2017-18 Johar Gadly Alias Zohar Mohammad Bhai ……………....Appellant Shop No.5, Aditya Arcade, Exhibition Road, Patna, Bihar- 800001. [Pan: Abopb7542H] Vs. Acit, Cc-2, Patna………….…..……………..………………….…..... Respondent Appearances By: Shri Hiresh Karan, 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 15, 2026 आदेश / Order Per Sonjoy Sarma: The Present Appeal Filed By The Assessee Is Directed Against The Order Dated 31.01.2025 Passed By The Cit(A)-3, Patna U/S 250 Of The Income Tax Act, 1961 (The ‘Act’) For The Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Filed Return Of Income Declaring A Total Income Of ₹2,94,100. The Assessing Officer Completed Assessment U/S 143(3) By Determining Total Income At Rs.8,63,000/- After Making Addition Of Rs.11,57,190/- On Account Of Unexplained Investment U/S 69 Of The Act.

Section 143(3)Section 250Section 69

assessee has now preferred an appeal before the Tribunal with a delay of 79 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

Manoj Dwivedi, Lucknow vs. ITO-3(1), Lucknow

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

ITA 619/LKW/2025[2016-17]Status: DisposedITAT Lucknow15 Jan 2026AY 2016-17

Bench: SHRI KUL BHARAT (Vice President), SHRI ANADEE NATH MISSHRA (Accountant Member)

For Appellant: Shri Ashwani Kumar, C.AFor Respondent: Shri Amit Kumar, CIT(DR)
Section 143(2)

conferencing even after requesting for the same. 3. That the Learned Court erred in law in the facts of the case by not condoning the delay in filing the appeal even after genuine hardships faced by the appellant on the medical grounds. Page 2 of 6 4. That the Learned ... dismissed the appeal without appreciating the facts in the right perspective. He further submitted that the Ld. CIT(A) failed to condone the delay, which had occurred due to the Page 3 of 6 “reasonable cause.” He also submitted that if an opportunity is granted to the assessee, he would

Income Tax Officer-2(1), Lucknow vs. Shyam Sagar Yadav, Lucknow

In the result, the appeal of the Revenue is dismissed

ITA 446/LKW/2024[2017-18]Status: DisposedITAT Lucknow15 Jan 2026AY 2017-18

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraआयकर अपील सं/ Ita No.446/Lkw/2024 ननिाारण वर्ा/ Assessment Year: 2017-18 Income Tax Officer-2(1) V. Shyam Sagar Yadav Room No.318, Plot No.57, 225, Jiamau, Hazratganj, Pratyaksh Kar Bhawan, Ram Lucknow-226001. Teerath Marg, Narhi, Lucknow- 226001. Pan:Bdkps3230A अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri Amit Kumar, Cit-(Dr) प्रत्यर्थी कक और से /Respondent By: Shri Shyam Sagar Yadav (Assessee In Person) Along With Shri P. K. Kapoor, C.A. & Shri Shailendra Mishra, Advocate (Providing Pro Bona Services To The Appellant) सुनवाई कक तारीख / Date Of Hearing: 08 01 2026 घोर्णा कक तारीख/ Date Of 15 01 2026 Pronouncement: आदेश / O R D E R

For Appellant: Shri Amit Kumar, CIT-(DR)For Respondent: Shri Shyam Sagar Yadav (
Section 115BSection 271ASection 69A

Income Tax Act.” Page 2 of 4 2. The appeal is time barred by 34 days. The Revenue has filed an application seeking condonation of delay in filing of appeal. After perusal of application, we have satisfied that delay in filing of appeal was for bonafide reasons

Jaswinder Singh, Ludhiana vs. Income Tax Officer, Ward-6(1), Ludhiana

The appeal stand allowed for statistical purposes

ITA 22/CHANDI/2025[2011-12]Status: DisposedITAT Chandigarh15 Jan 2026AY 2011-12

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.22/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2011-12) Shri Jaswinder Singh Ito Ward-6(1) 212-A, Ferozepur Road बनाम/ Vs. Aaykar Bhawan, Rishi Nagar, Rajguru Nagar, Ludhiana - 141001 Ludhiana "थायीलेखासं./जीआइआरसं./Pan/Gir No. Brgps-2619-F (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Ashwani Kumar (Ca) (Virtual) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) - Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 14-01-2026 घोषणाकीतारीख /Date Of Pronouncement : 15-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2011- 12 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 18-11-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] On Best Judgment Basis U/S 147 R.W.S. 144 Of The Act On 12-12-2018. The Only Prayer Of Ld. Ar Is To Restore The Assessment Back To The File Of Ld. Ao Which Has Been Opposed By Ld. Sr. Dr.

For Appellant: Sh. Ashwani Kumar (CA) (Virtual) – Ld. ARFor Respondent: Sh. Vivek Vardhan (Addl. CIT) - Sr. DR
Section 147

wherein Ld. AO made addition of cash deposit of Rs.25 Lacs. The Ld. CIT(A) did not admit the appeal for want of condonation of delay of 2 years and 10 months. Aggrieved, the assessee is in further appeal before us. 3. Keeping in mind the guiding principles laid down ... Apex Court in the case of Collector, Land Acquisition vs. Mst. Katiji & Ors. (1987; (2) TMI 61 SC), we condone the delay in first appeal. Since the assessment has been framed on ex-parte basis, we direct Ld. AO to frame de novo assessment with a direction to the assessee

Kotapaduprimary Agricultural Cooperative Society, Prakasam vs. ITO., Ward-1, Ongole

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

ITA 764/HYD/2025[2019-20]Status: DisposedITAT Hyderabad15 Jan 2026AY 2019-20

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.763 & 764/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2018-19 & 2019-20) Kotapadu Primary Vs. Income Tax Officer Agricultural Cooperative Ward – 1 Society, Prakasam Ongole Pan:Aabak5758P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C.A C. Subrahamanyam राज" व "ारा/Revenue By: Shri Sankar Pandit P, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 05/01/2026 घोषणा की तारीख/Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Kotapadu Primary Agricultural Cooperative Society (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Both Dated 28.02.2025 For The A.Y 2018-19 & A.Y. 2019-20 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Page 1 Of 7

For Appellant: C.A C. SubrahamanyamFor Respondent: Shri Sankar Pandit P, Sr. DR
Section 147Section 148Section 148ASection 151Section 249(3)

dismissed the appeal on the ground of limitation, holding that the assessee had failed to establish sufficient cause for condonation of delay as required under section 249(3) of the Act. 6. Aggrieved by the order of the Ld. CIT (A), the assessee is in further appeal before this Tribunal ... assessee has filed a petition for condonation of delay along with an affidavit explaining the reasons for the delay in filing the appeal before the Ld. CIT(A). It has been submitted that the assessee is a Primary Agricultural Cooperative Society having about 1,000 members and is engaged

Kotapadu Primary Agricultural Cooperative Society, Prakasam vs. ITO., Ward-1, Ongole

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

ITA 763/HYD/2025[2018-19]Status: DisposedITAT Hyderabad15 Jan 2026AY 2018-19

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.763 & 764/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2018-19 & 2019-20) Kotapadu Primary Vs. Income Tax Officer Agricultural Cooperative Ward – 1 Society, Prakasam Ongole Pan:Aabak5758P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: C.A C. Subrahamanyam राज" व "ारा/Revenue By: Shri Sankar Pandit P, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 05/01/2026 घोषणा की तारीख/Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Kotapadu Primary Agricultural Cooperative Society (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Both Dated 28.02.2025 For The A.Y 2018-19 & A.Y. 2019-20 Respectively. Since Identical Issues Are Involved In These Two Appeals, For The Sake Of Convenience, These Were Page 1 Of 7

For Appellant: C.A C. SubrahamanyamFor Respondent: Shri Sankar Pandit P, Sr. DR
Section 147Section 148Section 148ASection 151Section 249(3)

dismissed the appeal on the ground of limitation, holding that the assessee had failed to establish sufficient cause for condonation of delay as required under section 249(3) of the Act. 6. Aggrieved by the order of the Ld. CIT (A), the assessee is in further appeal before this Tribunal ... assessee has filed a petition for condonation of delay along with an affidavit explaining the reasons for the delay in filing the appeal before the Ld. CIT(A). It has been submitted that the assessee is a Primary Agricultural Cooperative Society having about 1,000 members and is engaged

S D Rai Prayas Educational Trust, Kolkata vs. Assessment Unit Ward 50(1), Kolkata

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

ITA 2495/KOL/2025[2020-21]Status: DisposedITAT Kolkata15 Jan 2026AY 2020-21

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2020-21 S D Rai Prayas Educational Trust……………..……….….……….……Appellant Flat No.Ge Building No.11, Brijdham Housing Complex, Canal Street, Vip Road, Shree Bhumi, North 24 Parganas, Kol-700048.. [Pan: Aavts2993M] Vs. Assessment Unit Ward-50(1), Kolkata …………..…….....……...…..…..Respondent

Section 10Section 144Section 250Section 274Section 5

Educational Trust 4.1 The ld. A.R. prayed that the matter may be remitted back to the ld. CIT(A) for fresh adjudication after condoning the delay. 5. The ld. DR supports the impugned order but did not raise any objection for remitting the appeal of the assessee before ... bona fides is imputable to the appellant." In N.Balakrishnan v. M.Krishnamurthy [1998 (7) SCC 123], this Court held: "It is axiomatic that condonation of delay is a matter of discretion of the court. Section 5 of the Limitation Act does not say that such discretion can be exercised only

Slo Automobiles Pvt. Ltd., Dehradun vs. DCIT, Dehradun

In the result, Appeal of the Assessee is allowed

ITA 6509/DEL/2016[2011-12]Status: DisposedITAT Dehradun14 Jan 2026AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Slo Automobiles Private Dy. Cit, Limited, Circle-2, Dehradun. 108-Haridwar Road, Vs. Dehradun-248001. Pan-Aancs8160M (Appellant) (Respondent)

Section 143(3)Section 148Section 43B

time of hearing. 3. There is a delay of 197 days in filing the Appeal. Assessee filed an application to condone the delay contending that the Managing Director of the Assessee went into acute depression and due to the adverse health condition, he was unable to pursue the matter ... Appeal on time, which resulted in filing the present appeal belatedly. 4. We have heard both the parties on the application for condonation of delay. The Hon'ble Supreme Court time and again clarified that the delay in filing the Appeal with sufficient cause should be looked into

Union Bank of India, Mumbai vs. DCIT, TDS Circle, Panaji

Appeals are DISMISSED

ITA 171/PAN/2025[2014-15]Status: DisposedITAT Panaji14 Jan 2026AY 2014-15

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr C Naresh [‘Ld. AR’]For Respondent: Ms Rijjula Uniyal [‘Ld. DR’]
Section 131Section 133ASection 194ASection 201Section 201(1)Section 250Section 253(1)

Managing committee of Raghunathpur Academy and Ors’ reported in [2013, 9 SCR 782 (SC)]; (a) Lack of bonafied imputable to a party seeking condonation of delay is a significant and relevant fact; (b) The concept of liberal approach has to encapsulate the conception of reasonableness and totally unfettered free play ... gets away with fraud, misrepresentation or interpolation by taking recourse to the technicalities of the law of limitation. (f) An application for condonation of delay should be drafted with careful concern and not in a haphazard manner harbouring notion that Courts are required to condone delay on bedrock of principle