2025 Supreme(Online)(ITAT) 5581

INCOME TAX APPELLATE TRIBUNAL (AGRA BENCH)
Sunil Kumar Singh, J, Manish Agarwal, ACJ
Aarush Jain Family Trust – Appellant
Versus
Income-tax Officer – Respondent
ITA No. 169 & 170/Agr/2025

Procedural laws must aid justice; significant delays, especially during exceptional circumstances like pandemics, can be condoned to ensure fair access to justice.

Headnote:(A) Income Tax Act, 1961 - Section 249 - Appeals dismissed by CIT(A) for delay - Reasonable explanation submitted for 2176 days delay not duly considered - COVID-19 pandemic period taken into account for delay condonation - Appeals allowed and matter restored for fresh consideration. (Paras 6-10)

(B) Justice and Procedural Law - Delay in appeals should be considered in the interest of justice unless strictly prohibited by statute - Courts should aid justice rather than obstruct it. (Paras 9-10)

Facts of the case:
The assessees filed appeals against the orders rejecting their claims for appeal condonation due to a significant delay attributed to misunderstandings regarding tax liability and limitations caused by the COVID-19 pandemic.

Findings of Court:
The court condoned the delay, noting that it was a substantial part of the delay that overlapped with the pandemic period, and emphasized that procedural rules should not obstruct justice.

Issues: Main issues included whether the delay in filing appeals was justified and whether the CIT(A) had properly considered the causes for the delay.

Ratio Decidendi: The court ruled that procedural constraints should not hinder the advance of justice and that sufficient cause should consider unique circumstances affecting the party’s ability to comply with timelines.

Result: Appeals allowed.