#Tax Appeals

ITAT Delhi has ruled that when an assessee submits credible medical grounds for delay in filing an appeal and the Revenue fails to rebut them, the tribunal must condone the delay to uphold substantive justice. This sets a critical precedent for taxpayers facing health-related procedural setbacks, reinforcing that technical defaults cannot override legitimate humanitarian concerns under the Income Tax Act.

ITAT Delhi condones a 3-year delay in filing an appeal against a penalty under Section 271(1)(c) IT Act, ruling that lack of legal awareness and procedural confusion constitute 'sufficient cause'. The decision underscores that assessees without professional assistance may seek relief from strict timelines where genuine ignorance is proven.

The Tribunal holds that revenue must prove delivery of orders via Speed Post with acknowledgment; mere dispatch is insufficient to trigger limitation period.

ITAT sets aside ex parte order against assessee for failure to respond, reaffirming that procedural fairness cannot be sacrificed even amid non-compliance.

ITAT Pune rules that ex-parte appellate orders under Section 250(6) must contain reasoned decisions on merits, not mere dismissal for non-prosecution. Key implications for tax litigation.

ITAT sets aside CIT(A) order for dismissing appeal on delay grounds, remands case for fresh consideration with opportunity to file condonation application.