Vinod Ramnath Rao Vs CIT(A) (ITAT Mumbai)
In Vinod Ramnath Rao vs. CIT(A) , the Mumbai Bench “F” of the Income Tax Appellate Tribunal (ITAT) dealt with an appeal for Assessment Year 2013–14 challenging both procedural and substantive aspects of an assessment framed under Section 143(3) of the Income-tax Act, 1961.
At the outset, the Tribunal considered a delay in filing the appeal. The assessee submitted an affidavit explaining that the delay was caused by extraordinary personal circumstances, including the critical illness and death of his mother in early 2023 and prolonged psychiatric treatment and hospitalisation of his daughter, including electroconvulsive therapy and further hospital admissions through early 2025. The assessee stated that he became aware of the appellate order only upon receipt of a penalty order dated 06.01.2025 under Section 271(1)(c), after which he promptly took steps to file the appeal. Relying on principles laid down by the Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Ors. and Mool Chandra v. Union of India, the Tribunal held that “sufficient cause” must receive a liberal and justice-oriented construction. Finding the explanation bona fide and supported by documentary evidence, the Tribunal condoned the delay and admitted the appeal for adjudication on merits.
