M.F. Textiles Pvt. Ltd. Vs ACIT (ITAT Chennai)
Summary: The Income Tax Appellate Tribunal, Chennai Bench, ‘A’ Bench, comprising Shri V. Durga Rao, Judicial Member and Shri G. Manjunatha, Accountant Member, disposed of ITA Nos. 578 & 579/Chny/2021 concerning Assessment Years 2013-14 and 2015-16. The appeals were directed against separate but identical orders of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 29.09.2021. Since the facts and issues were common, the appeals were heard together and disposed of by a consolidated order. The order was pronounced on 24.02.2022.
At the outset, the Tribunal noted that the appeals were barred by limitation by 11 days. The assessee sought condonation of the delay on the ground that the delay was meagre and deserved to be condoned in the interest of justice. After considering the condonation petition and hearing both sides, the Tribunal found that the reasons furnished for not filing the appeals within the prescribed period constituted reasonable cause. It accordingly condoned the delay and admitted the appeals for adjudication.
On merits, the relevant facts were that, for Assessment Years 2013-14 and 2015-16, the assessee had filed quarterly TDS returns in Forms 24Q and 26Q beyond the prescribed due dates. The Assessing Officer processed the quarterly TDS returns under Section 200A and levied late filing fee under Section 234E of the Income-tax Act, 1961.
