The
assessee preferred an appeal against the order passed by the Commissioner of
Income Tax (Appeals), Trichy, for Assessment Year 2011-12. There was a delay of
1510 days in filing the appeal. The assessee explained that the impugned order
was received during the COVID-19 pandemic and that the period from 15 March
2020 to 29 May 2022 was liable to be excluded in terms of the directions of the
Hon’ble Supreme Court. It was further submitted that after June 2022, the
assessee, being of advanced age, suffered from ill-health and was unable to
coordinate effectively with the tax consultant. The appeal was ultimately filed
after the assessee received recovery intimation from the Department in August
2024.
The
Tribunal, after considering the affidavit and submissions, held that the delay
was neither wilful nor deliberate and that the effective delay stood
substantially reduced after excluding the COVID-19 period. Being satisfied that
the delay was caused by circumstances beyond the control of the assessee, the Tribunal
condoned the delay and admitted the appeal for adjudication.
On
merits, the Tribunal observed that although the assessment was framed under
section 143(3) read with section 147, the final opportunity for hearing was
granted only on 30 November 2018. The assessee filed the return of income in
response to notice under section 148 on 21 December 2018, and notices under
sections 143(2) and 142(1) were issued thereafter. Despite the assessee’s
appearance on 28 December 2018, the assessment order was passed hurriedly on 30
December 2018.
The
Tribunal noted that the assessee was not afforded effective opportunity to
present the case either at the assessment stage or during the appellate
proceedings before the Commissioner (Appeals), which were virtually disposed of
ex-parte. Holding that the principles of natural justice were violated, the
Tribunal set aside the assessment and restored the matter to the file of the
Assessing Officer for de novo adjudication.
The
Tribunal directed that the reassessment be carried out after granting proper
opportunity of hearing to the assessee, subject to payment of costs of ₹40,000
to the Tamil Nadu State Legal Services Authority. The assessee was also
directed to cooperate and diligently prosecute the proceedings. The appeal was
allowed for statistical purposes.
Source Link- https://itat.gov.in/public/files/upload/1768291939-6uJegF-1-TO.pdf
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