Delay in filing appeals may be condoned for valid medical reasons, supporting judicial precedent underscores liberal approach towards genuine claims.

ORDER

PER MANJUNATHA G., A.M :

These appeals filed by the assessee are directed against the separate orders of Commissioner of Income Tax (Appeals) – 11, Hyderabad, dated 11.01.2023, pertains to the assessment years2017-18 to 2019-20. Since common issues are involved in all these three appeals, these appeals were heard together and are being disposed of by this single consolidated order for the sake of convenience and brevity.

2. At the outset, there is a delay of 692 days in filing the captioned appeals before the Tribunal. The learned counsel for the assessee Shri G. Srinivasa Rao, C.A. submitted that, an affidavit has been filed by the Director of the assessee company explaining the reasons for the delay in filing the appeals. It was submitted that, the delay was neither deliberate nor due to negligence, but occurred due to circumstances beyond the control of the assessee company, as detailed in the affidavit filed in support of the condonation petition. The learned counsel for the assessee explained that, the Director of the assessee company, who was responsible for managing its day-to-day affairs and pursuing tax matters, had been suffering from a psychiatric disorder namely “Dissociative Amnesia” coupled with high blood pressure and sugar levels since June, 2022. Due to this condition, he experienced memory loss, severe stress, and anxiety and had been undergoing continuous medical treatment at Medicover Hospitals, Hi-Tech City, Hyderabad. The assessee has also filed medical records issued by Medicover Hospitals to substantiate the treatment undergone by the Director of the assessee company. The learned counsel for the assessee further submitted that, because of the ill-ness, the Director of the assessee company was rendered incapable of pursuing the appeal proceedings before the learned CIT(A) and was also unaware of the appellate order passed by the learned CIT(A)-11, Hyderabad. Consequently, the appeals could not be filed before the Hon’ble Tribunal within the prescribed time limit. It was further submitted that, the Director of the assessee company came to know about the disposal of the said appeals only in February, 2025, when he received a call from the Income Tax Department informing him about the outstanding tax demand for A.Ys. 2017-18 to 2019-20 in the hands of the assessee company. Upon verification of the income tax portal, he realized that, the appeals filed before the CIT(A) had already been disposed of. Immediately thereafter, he contacted a senior Chartered Accountant and initiated steps for preparation and filing of the appeals before the Tribunal. Accordingly, the appeals were filed on 20.02.2025, resulting in a delay of 692 days.

3. The learned counsel for the assessee further submitted that, the delay was caused solely due to medical reasons and circumstances beyond the control of the assessee company and that, there was no lack of bona fide intention or deliberate inaction on its part. In view of the facts and circumstances explained in the affidavit filed by the Director, the learned counsel for the assessee prayed that, the delay of 692 days in filing the appeals before the Tribunal may kindly be condoned in the interest of justice and the appeals may be admitted and decided on merits.

4. The learned Sr. A.R. for the Revenue, Sri K. Krishna Moorthy, on the other hand, filed written submissions opposing the petition filed by the assessee seek