Infinio Techsole (India) Pvt. Ltd. Vs ITO (ITAT Hyderabad)
Summary: The Hyderabad ITAT dealt with three appeals filed by Infinio Techsole (India) Pvt. Ltd. concerning AY 2013-14, Quarters 2 to 4. The appeals arose from separate orders dated 11.12.2025 passed by the Addl/JCIT(A), Raipur. Since identical facts and issues were involved, the Tribunal heard the three matters together and disposed of them through a consolidated order. The underlying proceedings related to three separate orders dated 04.08.2023 passed by the Assessing Officer under section 154 read with section 200A in connection with quarterly TDS statements in Form No.26Q.
The grounds reproduced from ITA No.593/Hyd/2026 show that the assessee challenged, among other matters, late filing fee of Rs.30,824 under section 234E for delayed furnishing of the TDS return and interest of Rs.25,256 under section 220(2) for non-payment of the late filing fee. It also challenged the jurisdiction and validity of the orders under section 154 read with section 200A and alleged violation of principles of natural justice. The Tribunal, however, did not adjudicate any of these substantive grounds.
The immediate controversy before the Tribunal concerned the delay in filing the first appeals. The Addl/JCIT(A) had noticed that no affidavit had been filed in support of the petitions seeking condonation of delay and, on that basis, declined to condone the delay and dismissed all three appeals in limine without deciding the issues on merits. Before the Tribunal, the assessee produced duly sworn affidavits explaining the reasons for the delay and requested that, in the interest of substantial justice, the delay be considered and the appeals adjudicated on merits. The Departmental Representative relied upon the appellate orders.
