Smt. Palaniappan Manonmani Vs ITO (ITAT Chennai)
The Income Tax Appellate Tribunal (ITAT), Chennai, considered the assessee’s appeal against the order dated 18.02.2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for Assessment Year 2018-19. The Tribunal first dealt with a delay of 273 days in filing the appeal. The assessee, a senior citizen, submitted an affidavit stating that limited knowledge of the digital environment, advanced age, medical ailments, regular treatment, health check-ups, and advised bed rest prevented timely action. Medical records were also filed. The Tribunal found sufficient cause for the delay, held that no laches could be attributed to the assessee, condoned the delay, and proceeded to decide the appeal on merits.
The Tribunal noted that the appellate order was passed ex parte due to non-compliance with four notices issued by the First Appellate Authority (FAA). It also observed that the assessment had been completed on a best judgment basis under Sections 147, 144 and 144B of the Income-tax Act, 1961.
According to the assessee, she remained ex parte before the Assessing Officer (AO) due to lack of awareness of the proceedings and consequently the AO made an addition of ₹25,35,700 under Section 56(2)(x)(b) towards the difference between the stamp duty value and the purchase consideration of an immovable property, and a further addition of ₹60,00,000 under Section 69 treating the investment in the property as unexplained due to lack of evidence regarding the source of funds.
