Delay of 207 Days Not a Barrier as Tribunal Orders Fresh Merits-Based Hearing

SPA Soaps & Surfactants Vs DCIT (ITAT Chandigarh)

The appeal concerned an assessment for AY 2017–18, where the Assessing Officer made an addition of ₹20.31 lakh as unexplained cash deposits under a best-judgment assessment framed under Sections 144 and 147. The Commissioner of Income Tax (Appeals) dismissed the assessee’s appeal at the threshold, citing a delay of 207 days and refusing to condone it. The assessee appealed to the ITAT, arguing that the matter should be decided on merits and asserting readiness to substantiate its case. Considering the principles of natural

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