Dr. Reddy S Laboratories Limited Vs DCIT (ITAT Hyderabad)
The Hyderabad Bench of the Income Tax Appellate Tribunal (ITAT) considered the assessee’s appeal against the order dated 04.02.2026 passed by the Addl./JCIT(A), arising from an order under Sections 201(1) and 201(1A) of the Income Tax Act, 1961 for Assessment Year 2016-17. The CIT(A) had dismissed the assessee’s appeal in limine on the ground of limitation.
The assessee challenged the dismissal, contending that the underlying order under Sections 201(1) and 201(1A) read with Section 195 had initially been challenged before the High Court through a writ petition. According to the assessee, the writ petition was dismissed on 21.06.2023 on the ground that an alternative statutory remedy was available, following which the appeal was filed before the CIT(A). The assessee also contended that the delay occurred because it had pursued the writ remedy and that the period spent before the High Court should be excluded while considering limitation. It was further submitted that despite repeatedly requesting a virtual personal hearing, the CIT(A) dismissed the appeal without granting such hearing, thereby violating the principles of natural justice and Section 250(6).
The Revenue opposed the appeal, submitting that there was an inordinate delay of 1,649 days in filing the appeal before the CIT(A), that the assessee had failed to establish sufficient cause for condonation of delay, and that being a large corporate entity with legal and tax experts, it could not rely upon the plea of pursuing an alternative remedy.
