Hemlata Kamalakar Deo Vs ITO (ITAT Mumbai)
The Income Tax Appellate Tribunal (ITAT), Mumbai, considered an appeal filed by the assessee against the order dated 13.06.2024 passed under Section 250 of the Income Tax Act, 1961 for Assessment Year 2017-18.
At the outset, the Tribunal examined the delay in filing the appeal. The assessee, an 80-year-old senior citizen widow, filed an affidavit explaining that her late husband had earned his livelihood by performing bhikshuki services, pujas, and last rites, receiving payments only in cash. Following his death on 29.10.2014, the accumulated cash savings were inherited by her as stridhan. During demonetisation, she deposited these accumulated savings into her bank account by exchanging the old currency. Subsequently, scrutiny proceedings were initiated, culminating in an assessment under Section 144 dated 07.10.2019 making additions of Rs. 15,18,252.
The assessee further stated that she had no educational qualifications, lacked financial means to engage professional representation, and relied upon relatives for assistance in tax matters. According to the affidavit, she had not received the appellate order dated 05.10.2023 physically and became aware of it only after receiving a recovery-related call from the Income Tax Department. After her nephew accessed the income tax e-filing portal and informed her of the appellate order, she approached an advocate on a pro bono basis and thereafter filed the appeal before the Tribunal.
