Priyanka Lalitkumar Raizada Vs DCIT (ITAT Mumbai)
The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) considered an appeal filed by the assessee against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, which had upheld an assessment framed under Section 143(3) of the Income-tax Act, 1961 for Assessment Year 2014–15. The core dispute related to an addition of ₹21,50,540 made under Section 68 of the Act by treating the sale proceeds of jewellery as unexplained cash credits.
The appeal before the Tribunal was filed with a delay of 490 days. The assessee sought condonation of delay by explaining that during the relevant period her mother was suffering from cancer, which eventually led to her death in January 2024, causing emotional, financial, and personal distress. The assessee’s tax matters were being handled by her chartered accountant, who also fell seriously ill and later passed away in June 2025. After these events, the assessee engaged another professional who took steps to file the appeal. Death certificates of both her mother and the tax professional were placed on record. Considering these circumstances, the Tribunal found the reasons to be genuine and sufficient and accordingly condoned the delay.
