Renu Bala Vs ITO (ITAT Delhi)
The appeal was filed by the assessee against the order dated 13.10.2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, for Assessment Year 2016–17. The appeal before the Tribunal was delayed by 58 days. The assessee submitted an application supported by an affidavit explaining the reasons for the delay. Upon examination, the Tribunal found the delay to be unintentional and based on bona fide reasons, and accordingly condoned the delay and admitted the appeal.
The assessee contended that the CIT(A) had dismissed the appeal in limine on the ground of limitation, despite the delay of 125 days having been explained. It was argued that the CIT(A) failed to properly appreciate the reasons for the delay and dismissed the appeal without condoning it. The assessee further submitted that there was a prima facie case on merits which warranted consideration.
The Department, on the other hand, argued that the delay of 125 days before the CIT(A) was not supported by sufficient reasons and therefore the dismissal of the appeal was justified.
Upon hearing both sides and reviewing the record, the Tribunal observed that the CIT(A) had adopted a hyper-technical approach in dismissing the appeal solely on limitation grounds. It noted that the assessee had provided reasons for the delay, which were not adequately considered.
