Oxford Shiksha Samit Vs ITO (ITAT Agra)
The Income Tax Appellate Tribunal (ITAT), Agra Bench, has allowed two appeals filed by Oxford Shiksha Samit, setting aside the orders of the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi. The ITAT’s decision, pronounced on June 16, 2025, primarily addresses the issue of condonation of substantial delays in filing first appeals before the CIT (Appeals) for the assessment years 2018-19 and 2019-20.
The core of the dispute revolved around the CIT (Appeals)’s dismissal of Oxford Shiksha Samit’s appeals as barred by limitation, rejecting the assessee’s plea for condonation of delays amounting to 820 days and 873 days respectively. These appeals were filed on July 28, 2023, and July 29, 2023, against intimation orders under Section 143(1) of the Income-tax Act, 1961, dated March 29, 2021, and February 05, 2021.
Assessee’s Arguments and Delay Justification
During the ITAT proceedings, the learned representative for Oxford Shiksha Samit contended that the CIT (Appeals) had overlooked the directives of the Hon’ble Supreme Court regarding the global COVID-19 pandemic. The assessee submitted that a significant portion of the delay in filing the appeals overlapped with the pandemic period. The common reason provided for the delay was that the intimation regarding the demand for Assessment Year 2018-19 was “overlooked” due to COVID-19, and the issue only came to light upon checking the e-filing compliance portal, prompting the filing of the appeals. The assessee sought the setting aside of the impugned orders and restoration of the matters to the CIT (Appeals) for a decision on merits after providing adequate opportunity.
