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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

Yogesh Sood, Bhopal vs. Income Tax Officer-1(2), Bhopal

In the result we are of the considered opinion that the

ITA 424/IND/2025[2018-2019]Status: HeardITAT Indore09 Jan 2026AY 2018-2019
Section 132Section 132(4)Section 147Section 148Section 246ASection 69C

dated 19.12.2024 & instant appeal ought to have been filed on or before 17.02.2025 however the instant appeal was filed on 05.05.2025. A condonation of delay application along with an affidavit in support is placed on record of this Tribunal. With regard to the delay it was submitted that the Assessee ... delay in filing of first appeal is not wilful & that thereis no malafide intention. Delay is not deliberate. The prayer was made to condone the delay. Affidavit date 03.05.2025 was relied upon & placed on record too. In summation following was also submitted with regard to issue of delay

Rajnesh Kumar, Sitapur vs. The Income Tax Officer, Sitapur

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

ITA 304/LKW/2025[2015-16]Status: DisposedITAT Lucknow09 Jan 2026AY 2015-16

Bench: Shri Kul Bharat & Shri Nikhil Choudhary

For Appellant: Shri K. R. Rastogi, CAFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)
Section 271(1)(b)Section 44ASection 69A

Lower authorities.” 3. It is noted that the appeal is barred by limitation for 235 days. The assessee has filed an application seeking condonation of delay along with supporting affidavit. Ld. Counsel for the assessee Shri K. R. Rastogi, CA reiterated the submissions as made in the application seeking condonation ... period. Due to such medical exigency, the appeal could not be filed in time by the Ld. counsel, nor could a petition seeking condonation of delay be submitted. Further, he took us through the medical reports of Shri Ayaz Ahmad Ayyubi, Advocate. Under the facts and circumstances

Rajnesh Kumar, Sitapur vs. The Income Tax Officer, Sitapur

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

ITA 303/LKW/2025[2015-16]Status: DisposedITAT Lucknow09 Jan 2026AY 2015-16

Bench: Shri Kul Bharat & Shri Nikhil Choudhary

For Appellant: Shri K. R. Rastogi, CAFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)
Section 271(1)(b)Section 44ASection 69A

Lower authorities.” 3. It is noted that the appeal is barred by limitation for 235 days. The assessee has filed an application seeking condonation of delay along with supporting affidavit. Ld. Counsel for the assessee Shri K. R. Rastogi, CA reiterated the submissions as made in the application seeking condonation ... period. Due to such medical exigency, the appeal could not be filed in time by the Ld. counsel, nor could a petition seeking condonation of delay be submitted. Further, he took us through the medical reports of Shri Ayaz Ahmad Ayyubi, Advocate. Under the facts and circumstances

Rajnesh Kumar, Sitapur vs. The Income Tax Officer, Sitapur

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

ITA 302/LKW/2025[2015-16]Status: DisposedITAT Lucknow09 Jan 2026AY 2015-16

Bench: Shri Kul Bharat & Shri Nikhil Choudhary

For Appellant: Shri K. R. Rastogi, CAFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)
Section 271(1)(b)Section 44ASection 69A

Lower authorities.” 3. It is noted that the appeal is barred by limitation for 235 days. The assessee has filed an application seeking condonation of delay along with supporting affidavit. Ld. Counsel for the assessee Shri K. R. Rastogi, CA reiterated the submissions as made in the application seeking condonation ... period. Due to such medical exigency, the appeal could not be filed in time by the Ld. counsel, nor could a petition seeking condonation of delay be submitted. Further, he took us through the medical reports of Shri Ayaz Ahmad Ayyubi, Advocate. Under the facts and circumstances

Rajnesh Kumar, Sitapur vs. The Income Tax Officer, Sitapur

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

ITA 301/LKW/2025[2015-16]Status: DisposedITAT Lucknow09 Jan 2026AY 2015-16

Bench: Shri Kul Bharat & Shri Nikhil Choudhary

For Appellant: Shri K. R. Rastogi, CAFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)
Section 271(1)(b)Section 44ASection 69A

Lower authorities.” 3. It is noted that the appeal is barred by limitation for 235 days. The assessee has filed an application seeking condonation of delay along with supporting affidavit. Ld. Counsel for the assessee Shri K. R. Rastogi, CA reiterated the submissions as made in the application seeking condonation ... period. Due to such medical exigency, the appeal could not be filed in time by the Ld. counsel, nor could a petition seeking condonation of delay be submitted. Further, he took us through the medical reports of Shri Ayaz Ahmad Ayyubi, Advocate. Under the facts and circumstances

Manmohan Singh & Sons, Ludhiana vs. CIT(A), Ludhiana

In the result, the appeal of the assessee is allowed for statistical purposes, subject to payment of cost as directed above

ITA 675/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh09 Jan 2026AY 2019-20

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

For Appellant: NoneFor Respondent: Shri Rajat Kumar Kureel, CIT, DR
Section 145(3)Section 147Section 148Section 69Section 69A

pointed out that both the above appeals are barred by limitation by seven days, for which the assessee has filed separate applications seeking condonation of delay. Considering the reasons explained therein and in the interest of substantial justice, the delay of seven days in both the appeals is hereby condoned

Manmohan Singh & Sons, Ludhiana vs. CIT(A), Ludhiana

In the result, the appeal of the assessee is allowed for statistical purposes, subject to payment of cost as directed above

ITA 674/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh09 Jan 2026AY 2018-19
For Appellant: NoneFor Respondent: Shri Rajat Kumar Kureel, CIT, DR
Section 145(3)Section 147Section 148Section 69Section 69A

pointed out that both the above appeals are barred by limitation by seven days, for which the assessee has filed separate applications seeking condonation of delay. Considering the reasons explained therein and in the interest of substantial justice, the delay of seven days in both the appeals is hereby condoned

Premilaben Bhavuji Thakor, Ahmedabad vs. The ITO, Ward - 3(2)(1), Ahmedabad

The appeal of the assessee is treated as allowed for statistical purposes

ITA 1944/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad09 Jan 2026AY 2016-17

Bench: Shri Sanjay Gargआयकर अपील सं /Ita Nos.1943 & 1944/Ahd/2025 िनधा"रण वष" /Assessment Year : 2016-17 Premilaben Bhavuji Thakor The Ito बनाम/ A/67, Dwarkapuri Mafalipur Ward-3(2)(1) V/S. Dholka Ahmedabad – 380 015 Ahmdabad – 382 006 "थायी लेखा सं./Pan: Aynpt 8295 P (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Pritesh Shah, Ca Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 08/01/2026 घोषणा की तारीख /Date Of Pronouncement: 09/01/2026 आदेश/O R D E R

For Appellant: Shri Pritesh Shah, CAFor Respondent: Smt. Mamta Singh, Sr.DR
Section 147Section 250Section 271(1)(c)

outset, it is noticed that the appeal of the assessee is time-barred by 14 days. A separate application/affidavit for condonation of delay has been filed. After considering the averments made in the said application/affidavit, the short delay in filing the appeal is hereby condoned. 3.1. It is also noticed ... dismissed that the delay in filing the appeal of the assessee being barred by limitation of 289 days. An application for condonation of delay was filed before the Ld. CIT(A), wherein, it was pleaded that the assessee was misguided by the Registered Income Tax Practitioner (ITP), who was consulted

Premilaben Bhavuji Thakor, Ahmedabad vs. The ITO, Ward - 3(2)(1), Ahmedabad

The appeal of the assessee is treated as allowed for statistical purposes

ITA 1943/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad09 Jan 2026AY 2016-17

Bench: Shri Sanjay Gargआयकर अपील सं /Ita Nos.1943 & 1944/Ahd/2025 िनधा"रण वष" /Assessment Year : 2016-17 Premilaben Bhavuji Thakor The Ito बनाम/ A/67, Dwarkapuri Mafalipur Ward-3(2)(1) V/S. Dholka Ahmedabad – 380 015 Ahmdabad – 382 006 "थायी लेखा सं./Pan: Aynpt 8295 P (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Pritesh Shah, Ca Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 08/01/2026 घोषणा की तारीख /Date Of Pronouncement: 09/01/2026 आदेश/O R D E R

For Appellant: Shri Pritesh Shah, CAFor Respondent: Smt. Mamta Singh, Sr.DR
Section 147Section 250Section 271(1)(c)

outset, it is noticed that the appeal of the assessee is time-barred by 14 days. A separate application/affidavit for condonation of delay has been filed. After considering the averments made in the said application/affidavit, the short delay in filing the appeal is hereby condoned. 3.1. It is also noticed ... dismissed that the delay in filing the appeal of the assessee being barred by limitation of 289 days. An application for condonation of delay was filed before the Ld. CIT(A), wherein, it was pleaded that the assessee was misguided by the Registered Income Tax Practitioner (ITP), who was consulted

Kishore Kashinath Koli, Panvel vs. CIT(A), Delhi

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

ITA 2179/PUN/2025[2018-19]Status: DisposedITAT Pune09 Jan 2026AY 2018-19

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2018-19

For Appellant: Mrs. Naina ChaurasiaFor Respondent: Shri Basavaraj Hiremath, Addl.CIT
Section 142(1)Section 147Section 148Section 148ASection 69

appeal with a delay of 125 days before the Ld. CIT(A) / NFAC, the Ld. CIT(A) / NFAC dismissed the appeal by not condoning the delay on the ground that the assessee has not filed any application for condonation of delay. 3 5. Aggrieved with such order ... submission of the Ld. Counsel for the assessee that the Ld. CIT(A) / NFAC should have considered the same as reasonable cause and condoned the delay and decided the appeal on merit. 9. We find the Hon'ble Supreme Court in the case of Collector, Land Acquisition vs. Mst. Katiji

Mahathi Engineering Industries Private Limited, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

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

ITA 802/HYD/2025[2018-19]Status: DisposedITAT Hyderabad09 Jan 2026AY 2018-19

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 143(3)Section 263

outset, we find that, there is a delay of 360 days in the appeal filed by the assessee for which a petition for condonation of delay, along with an affidavit explaining the reasons, have been filed. The learned counsel for the assessee, Shri Mohd. Afzal, Advocate, referring to the petition ... Revenue, Dr. Narendra Kumar Naik, on the other hand, strongly opposed the petition filed by the assessee for condonation of delay and argued that, the reasons given by the assessee do not come under ‘sufficient cause’ for considering huge delay of 360 days in filing the appeal

Sri Raghvendra Agro Industries, Mantralayam vs. Income Tax Officer, Ward 1, Adoni

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

ITA 34/HYD/2025[2023-24]Status: DisposedITAT Hyderabad09 Jan 2026AY 2023-24

Bench: The Tribunal. In This Regard, The Assessee Has Filed An Affidavit Sworn By Shri Archaka Vyasarajachar, Partner Of The Assessee Firm, Explaining The Facts Relating To Filing Of The Appeal. As Per The Affidavit, The Order Of The Ld. Cit(A) Was Served On The Assessee On 25.09.2024 & The Appeal Before The Tribunal Was Required To Be Filed On Or Before 24.11.2024. The Assessee Submitted That, Form No. 36, As Per The Prescribed Procedure, Was Filed Electronically On 20.11.2024, Which Is Within The Period Of Limitation.

Section 143(1)Section 40Section 44A

within the prescribed time limit, there is no delay in 3 Sri Raghavendra Agro Industries filing the appeal and, therefore, the question of condonation of delay does not arise. 4. The Ld. Senior A.R. for the Revenue, Shri K. Vinoth Kannan, on the other hand, relied upon the objection raised ... assessee filed an appeal challenging the intimation issued under Section 143(1) of the Act and also sought condonation of delay of 11 days in filing the appeal. During the appellate proceedings, the assessee filed written submissions along with supporting documents, including a revised tax audit report, contending that

Thilak Babu Boppana, Chittor vs. Income Tax Officer, Ward-1(1), Tirupati

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 1628/HYD/2025[2020-21]Status: DisposedITAT Hyderabad09 Jan 2026AY 2020-21

Bench: Shri Manjunatha G. (Accountant Member), Shri Ravish Sood (Judicial Member)

For Appellant: Shri M.M. Shabid SameerFor Respondent: Shri K. Vinoth Kannan, Sr
Section 144Section 147Section 148Section 148A

circumstances, therefore, the same merits to be condoned. Our aforesaid view that a liberal approach should be taken while considering an application seeking condonation of delay is supported by the judgment of the Hon’ble Supreme Court in the case of Vidya Shankar Jaiswal vs. The Income Tax Officer, Ward ... Apex Court while setting aside the order of the Hon'ble High Court of Chhattisgarh, which had approved the declining of the condonation of delay of 166 days by the Income-Tax Appellate Tribunal, Raipur Bench, had observed, that a justice-oriented and liberal approach should be adopted while

Sreemath Khadri Lakhsmi Narasimhaswamy Devasthanam, Kadiri vs. Income Tax Officer, Exemption Ward, Tirupati

In the result, appeals of the Assessee are allowed for statistical purposes

ITA 1479/HYD/2025[2023-24]Status: DisposedITAT Hyderabad09 Jan 2026AY 2023-24

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1477, 1478 & 1479/Hyd/2025 Assessment Years 2016-2017, 2022-2023 & 2023-2024 Sreemath Khadri Lakhsmi The Income Tax Officer, Narasimhaswamy Vs. Exemption Ward, Devasthanam, Kadiri Tirupati – 517 507. Andhra Pradesh. Pin – 515 591. Pan Aaajs5401M (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pv Raghavendra Kumar राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 06.01.2026 घोषणा की तारीख/Pronouncement: 09.01.2026 आदेश/Order

For Appellant: CA PV Raghavendra KumarFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 139(1)Section 142(1)Section 144Section 147Section 148Section 69A

Form No.10AC. However, the learned CIT(A) without deciding the appeal on merits, dismissed the appeal of the assessee in limine by not condoning the delay in filing of these appeals. 4. Aggrieved by the Orders of the learned CIT(A), the assessee is now, in appeals before the Tribunal ... period of limitation before the learned CIT(A). He, therefore, pleaded that, one more opportunity may please be provided to the assessee by condoning the delay in filing the appeals before the learned CIT(A). Further, since the Assessing Officer has passed ex-parte orders, the appeals may be remitted

Sreemath Khadiri Lakshmi Narasimha Swamy Devasthanam, Kadiri vs. Income Tax Officer, Exemption Ward, Tirupati

In the result, appeals of the Assessee are allowed

ITA 1478/HYD/2025[2022-23]Status: DisposedITAT Hyderabad09 Jan 2026AY 2022-23

Bench: Shri Manjunatha G. & Shri Ravish Sood

For Appellant: CA PV Raghavendra KumarFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 139(1)Section 142(1)Section 144Section 147Section 148Section 69A

Form No.10AC. However, the learned CIT(A) without deciding the appeal on merits, dismissed the appeal of the assessee in limine by not condoning the delay in filing of these appeals. 4. Aggrieved by the Orders of the learned CIT(A), the assessee is now, in appeals before the Tribunal ... period of limitation before the learned CIT(A). He, therefore, pleaded that, one more opportunity may please be provided to the assessee by condoning the delay in filing the appeals before the learned CIT(A). Further, since the Assessing Officer has passed ex-parte orders, the appeals may be remitted

Sreemath Khadri Lakhsmi Narasimha Swamydevasthanam, Kadiri vs. ITO., Exemption Ward, Tirupati

In the result, appeals of the Assessee are allowed for statistical purposes

ITA 1477/HYD/2025[2016-17]Status: DisposedITAT Hyderabad09 Jan 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1477, 1478 & 1479/Hyd/2025 Assessment Years 2016-2017, 2022-2023 & 2023-2024 Sreemath Khadri Lakhsmi The Income Tax Officer, Narasimhaswamy Vs. Exemption Ward, Devasthanam, Kadiri Tirupati – 517 507. Andhra Pradesh. Pin – 515 591. Pan Aaajs5401M (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pv Raghavendra Kumar राज" व "ारा /Revenue By: Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 06.01.2026 घोषणा की तारीख/Pronouncement: 09.01.2026 आदेश/Order

For Appellant: CA PV Raghavendra KumarFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 139(1)Section 142(1)Section 144Section 147Section 148Section 69A

Form No.10AC. However, the learned CIT(A) without deciding the appeal on merits, dismissed the appeal of the assessee in limine by not condoning the delay in filing of these appeals. 4. Aggrieved by the Orders of the learned CIT(A), the assessee is now, in appeals before the Tribunal ... period of limitation before the learned CIT(A). He, therefore, pleaded that, one more opportunity may please be provided to the assessee by condoning the delay in filing the appeals before the learned CIT(A). Further, since the Assessing Officer has passed ex-parte orders, the appeals may be remitted

Mumtaz Ali Mohd, Hyderabad vs. Income Tax Officer, Ward-8(1), Hyderabad

ITA 1260/HYD/2024[2014-15]Status: DisposedITAT Hyderabad09 Jan 2026AY 2014-15

Bench: Shri Manjunatha G. & Shri Ravish Sood(Hybrid Hearing) आ.अपी.सं /Ita No.1260/Hyd/2024 (िनधा"रण वष"/Assessment Year:2014-15) Mumtaz Ali Mohd, Vs. Income Tax Officer, Hyderabad. Ward-8(1), Pan: Abppm6593E Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By: Shri K. Vonoth Kannan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/01/2026 घोषणा की तारीख/Date Of 09/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 09/01/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 12/05/2023 For The Assessment Year (Ay) 2014-15. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri K. Vonoth Kannan
Section 147Section 148Section 148ASection 68

justice be condoned. 11. Per contra, Shri V. Vinoth Kannan, Learned Senior Departmental Representative (for short, “Ld. Sr.DR”) objected to the seeking of condonation of delay in filing of the present appeal. 12. We have given thoughtful consideration to the facts leading to the delay in filing the present appeal ... delay therein involved merits to be condoned. Our aforesaid view that a liberal approach should be taken while considering an application seeking condonation of delay is supported by the judgment of the Hon’ble Supreme Court in the case of Vidya Shankar Jaiswal vs. The Income Tax Officer, Ward

Sangeeta Motilal Shahani, Mumbai vs. ITO 27(3)(1), Vashi Navi Mumbai

ITA 7078/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Jan 2026AY 2013-14

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Jayant Bhatt, ARFor Respondent: Shri Asnkit Tiwari, Sr. AR
Section 143(1)Section 143(3)Section 68

assessee was barred by limitation being filed with a delay of 185 days. To explain the reasons for aforesaid delay, an application for condonation of delay has been filed by the assessee along with affidavit to claim that the delay was occasioned on account of reasons beyond the control ... assessee. We have considered the contents of the petition for condonation of delay along with the affidavit of the assessee and find substance in the submissions of the assessee that the delay was occasioned under bonafide error without any malafide intent or intentional act of the assessee. Neither any submission

Holy Cross Church, Mumbai vs. Income Tax Officer Exemption Ward 1(3), Mumbai

In the result, appeal of the assessee bearing ITA No

ITA 5515/MUM/2025[2023-24]Status: DisposedITAT Mumbai09 Jan 2026AY 2023-24

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Ms. Vasanti B. Patel a/w Shri M.A. GoelFor Respondent: Shri Ritesh Misra (CIT DR)
Section 11Section 11(2)Section 11(3)Section 143(1)Section 250

filed an appeal before the Ld. CIT(A). The Ld. CIT(A) rejected the appeal of the assessee on the ground that for condoning the delay for late filing Form No. 10BB is under jurisdiction of Ld. CIT(Exemption) and rejected the claim ... considers that Respondent No.1 never doubted the factual situation put forth by the Petitioner to explain the delay, Respondent No.1 ought to have condoned the delay. We find that if this delay is not condoned, there will be genuine hardship to the Petitioner, inasmuch as, the Petitioner would be denied

Reliable Enterprises, Mumbai vs. Income Tax Officer Ward 4(1), Thane

ITA 4812/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Jan 2026AY 2014-15

Bench: the Learned CIT(A). However, the

For Appellant: Ms. Sakina AmreliwalaFor Respondent: Shri Annavaran Kosuri
Section 144Section 147Section 271(1)(c)

submissions filed by the Assessee on 02/09/2022 vide Acknowledgment No.465938911020922. We also note that the Learned CIT(A) has rejected application seeking condonation of delay without considering the explanation offered by the Assessee in Memorandum of Appeal in Form 35 filed by the Assessee. The explanation provided has been rejected ... levy of penalty under Section 271(1)(c) of the Act. The Learned CIT(A) is directed to adjudicate the applications seeking condonation of delay and the appeal afresh as per law after granting the Assessee a reasonable opportunity of being heard. Accordingly, Ground No.3 raised by the Assessee