#Section 249(3) IT Act

ITAT Delhi has ruled that a 175-day delay in filing an income tax appeal must be condoned when the delay stems from genuine hardship, affirming that procedural rigidity cannot override the core principle of substantial justice. This reinforces that appellate authorities must interpret condonation provisions liberally to ensure access to justice for taxpayers, especially where no prejudice is shown to the revenue.

ITAT Delhi has ruled that delays of nearly five years in filing income tax appeals may be condoned under Section 249(3) if denying relief would result in a miscarriage of justice, emphasizing that technical limitations must yield to substantive fairness. This sets a critical precedent for taxpayers facing prolonged administrative delays, reinforcing that procedural rigidity cannot override equitable outcomes in tax adjudication.

ITAT Agra condones an unprecedented 1891-day delay in filing an income tax appeal, relying on the Supreme Court's exclusion of the limitation period from 15.03.2020 to 28.02.2022 due to the COVID-19 pandemic. The ruling underscores that assessees cannot be penalized for delays attributable to extraordinary circumstances beyond their control, even in cases of extreme procedural lapses.