Ecoslag Cements And Additives Pvt. Ltd. Vs JCIT (ITAT Panaji)
The Income Tax Appellate Tribunal (ITAT), Panaji Bench, on July 26, 2025, set aside an order by the National Faceless Appeal Centre (NFAC) that had dismissed an appeal by Ecoslag Cements And Additives Pvt. Ltd., citing a hyper-technical ground of being time-barred by one day. The ITAT ruled that the appeal was, in fact, filed within the prescribed time limit and emphasized the need for a justice-oriented approach by quasi-judicial authorities.
The case involved a penalty order issued by the Joint Commissioner of Income Tax, Panaji, on August 30, 2022, for Assessment Year 2019-20. This penalty order was received by Ecoslag Cements And Additives Pvt. Ltd. on September 13, 2022. According to Section 249(2) of the Income-tax Act, 1961, an appeal against such an order must be filed within 30 days. This meant the deadline for filing the appeal was October 13, 2022.
The assessee filed its appeal before the NFAC on October 13, 2022. However, the NFAC dismissed the appeal in limine (at the very beginning), stating it was time-barred by one day and that no condonation petition or affidavit explaining the delay was filed. This dismissal led the assessee to approach the ITAT, alleging a violation of natural justice.
