Rohit Jain Vs ITO (ITAT Chandigarh)
The appeals concern two matters filed by the assessee before the ITAT Chandigarh. The first appeal, ITA No. 451/CHD/2025, challenges quantum additions confirmed by the CIT(A). The second appeal, ITA No. 452/CHD/2025, relates to the penalty imposed under Section 271(1)(c) for the same assessment year 2013–14.
Condonation of Delay
In ITA No. 451/CHD/2025, the assessee filed the appeal with a delay of 1,350 days. An application for condonation explained that the assessee was a partner in a firm that suffered major losses and closed its operations in financial year 2015. As the business premises had shut down, notices issued by the CIT(A) were not received. The assessee’s father also passed away after a long illness, and this period was followed by the onset of Covid. According to the assessee, he remained unaware of the appellate proceedings and the order passed. Even the counsel did not inform him about the pending matter, and only upon receiving a recovery notice did the assessee become aware of the order and file the appeal. The assessee submitted that he had a fair case on merits and that the delay occurred due to circumstances beyond his control. After considering the submissions and affidavit, the Tribunal condoned the delay.
