Next Automotive Era Pvt. Ltd. Vs ITO (ITAT Delhi)
ITAT Condoned 134-Day Delay: Waiting for Section 154 Outcome Held a Bona Fide Reason
The Delhi ITAT held that a 134-day delay in filing an appeal before the CIT(A) deserved to be condoned where the assessee had first pursued a rectification application under Section 154 and was awaiting its disposal.
The assessee had filed a rectification application immediately after receiving the assessment order and reasonably believed that if the mistakes were rectified, there would be no necessity to file an appeal. Only after the Assessing Officer rejected the rectification application did the assessee file the appeal, resulting in the delay.
The Tribunal observed that the delay was caused by bona fide circumstances and not due to negligence, inaction, or lack of good faith. Relying on the Supreme Court’s decision in Ram Nath Sao v. Gobardhan Sao, the ITAT reiterated that the expression “sufficient cause” should receive a liberal interpretation to advance substantial justice and that acceptance of a genuine explanation should be the rule rather than the exception.
Accordingly, the Tribunal condoned the delay, set aside the order dismissing the appeal in limine, and restored the matter to the CIT(A) for adjudication on merits after providing adequate opportunity to the assessee.
FULL TEXT OF THE ORDER OF ITAT DELHI
This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre(NFAC) [in short ‘CIT(A)’] dated 19.2.2026, for assessment year 2020-21.
