Case Analysis: ITA 1426/DEL/2022 – Indrawati’s Appeal Against CPC Assessment Order for AY 2018-19

In the Income Tax Appellate Tribunal Delhi Bench ‘C’, the case of ITA 1426/DEL/2022 was heard, involving the appellant Indrawati from Nagal Kheri, Panipat, and the respondent, ITO Ward-2, Panipat. This case pertains to the assessment year 2018-19, wherein a significant judicial discourse unfolded, culminating in a noteworthy verdict.

The assessment orders in question, both dated 18.08.2020, passed under Section 154 of the Income Tax Act, 1961, were challenged by Indrawati concerning the assessment years 2017-18 and 2018-19. The core of the dispute revolved around the orders of the Commissioner of Income Tax (Appeals) NFAC, Delhi, which were dismissed on grounds of delay in filing the appeal against the intimation/order passed by the Centralized Processing Centre, Bangalore.

The arguments presented by Indrawati highlighted various legal and procedural lapses, including the infringement of the principles of Natural Justice due to inadequate opportunity provided to explain the reason for the appeal’s delay. The appellant, described as a humble rural agriculturist/farmer with no formal educational qualification nor taxable income for the year, contested the hyper-technical approach adopted by the CIT(A), arguing it contravened the law laid down by the Supreme Court in several landmark cases.

Despite the absence of the appellant during the hearing, the tribunal thoroughly examined the merits of the case. Referencing the judgments in the cases of Collector, Land Acquisition vs. Mst. Katiji and others, the tribunal underscored the importance of a liberal approach towards the condonation of delay, especially given the circumstances underpinned by the COVID-19 pandemic.

The tribunal’s analysis brought to light the reasonable explanations offered for the delay, juxtaposed against the backdrop of the appellant’s socio-economic status and the extraordinary pandemic circumstances. Emphasizing the principles of substantial justice over technicalities, the final judgment condoned the delay in filing the appeal and mandated a de novo adjudication on the merits of the case by the CIT(A).

This case sheds light on the judiciary’s balancing act between adhering to procedural statutes and ensuring that justice is served, highlighting the empathetic consideration given to appellants affected by unforeseen global crises. The decision also serves as a precedent for similar cases where delays might arise due to compelling reasons beyond the appellant’s control.

In concluding, both appeals were allowed for statistical purposes, marking a significant victory for Indrawati and setting a judicial benchmark for flexibility in the face of exceptional circumstances. The case illustrates the Income Tax Tribunal’s commitment to justice, demonstrating an understanding that legal processes should facilitate, rather than obstruct, the attainment of justice.

Order pronounced in the open Court on 19/04/2023 by both the judicial and accountant members, thus bringing a significant chapter in tax litigation to a close. This nuanced analysis of ITA 1426/DEL/2022 underscores the intricate interplay between law, justice, and the human condition, resonating with legal practitioners and taxpayers alike.

Case Analysis: ITA 1426/DEL/2022 – Indrawati’s Appeal Against CPC Assessment Order for AY 2018-19