Saint Gurmeet Ram Rahim Singh Insan Vs DCIT/ACIT (ITAT Chandigarh)
The Income Tax Appellate Tribunal (ITAT), Chandigarh allowed the assessee’s appeal for statistical purposes after holding that the delay in filing the appeal before the Commissioner of Income Tax (Appeals) deserved to be condoned in the interest of substantial justice. The Tribunal set aside the order of the CIT(A), who had dismissed the appeal as barred by limitation without examining the issues on merits.
For Assessment Year 2011-12, the assessee had filed a return declaring income of ₹1,77,840 and agricultural income of ₹9,85,800. The return was initially processed under Section 143(1) of the Income-tax Act. Subsequently, the assessment was reopened under Section 147, and an order under Sections 143(3) read with 147 determined the total income at ₹18,51,290. The Assessing Officer treated the agricultural income as income from undisclosed sources, made an addition of ₹6,87,650 on account of sundry debtors, and raised a tax and interest demand of ₹7,95,560.
The assessee filed an appeal before the CIT(A) with a delay of about 227 days. In seeking condonation, the assessee explained that he was lodged in Central Jail, Ambala during the relevant period and was unable to complete the procedural requirements for mandatory electronic filing. He stated that efforts were made to obtain a fresh digital signature through court directions and, when those efforts failed, steps were taken to authorise a representative on the e-filing portal. According to the assessee, the delay resulted entirely from circumstances beyond his control.
