Selvaraj Charitable Trust Vs ITO (Exemptions) (ITAT Chennai)
Law Aids the Vigilant, Not those Who Sleep over Their Rights – Charity May Begin at Home, But Not in Limitation Law -When Time Runs Out, So Does Charity- ITAT Rejects Trust’s 6-Year-Late Appeal – no sufficient cause shown for condonation
Assessee, Selvaraj Charitable Trust filed appeal before the Tribunal against the order of CIT(A), Delhi (NFAC) dated 11.06.2025, which had upheld the addition of ₹21,97,445 made in the intimation u/s 143(1) for AY 2015-16. CIT(A) had dismissed the appeal solely on the ground of an inordinate delay of 2336 days in filing the appeal, holding that no satisfactory reason was given for such a long delay except the claim that the managing trustee was suffering from heart ailments.
Before the Tribunal, Assessee remained absent and unrepresented. The Departmental Representative supported the orders of the lower authorities and argued that the CIT(A) rightly rejected the appeal since the Trust had failed to explain the cause for delay.
After examining the record, the Tribunal noted that the CIT(A) had carefully analyzed the reasons cited and correctly held that the explanation lacked credibility or sufficient cause for condonation. The Bench observed that “law aids the vigilant, not those who sleep over their rights,” and since the Assessee neither appeared before the Tribunal nor produced any fresh evidence to justify the delay, there was no ground to interfere.
