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2026 Supreme(Online)(ITAT) 2391

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Sandeep Gosain, Judicial Member, Bijayananda Pruseth, Accountant Member
Uttar Bhartiiya Education Society – Appellant
Versus
ITO – Respondent


Advocates:
For the Appellants/Petitioners: Kurpa Shah
For the Respondents: Kavitha Kaushik (SR DR)

Table of Content
1. appeals against cit(a) dismissal for delay in filing. (Para 1 , 2 , 3)
2. facts of delayed appeals post-143(1) intimation. (Para 4 , 17)
3. parties' submissions on delay condonation. (Para 5 , 6)
4. no sufficient cause for inordinate delay; limitation strict. (Para 7 , 8 , 9 , 10 , 11 , 12 , 13 , 14)
5. appeals dismissed; merits not considered. (Para 15 , 16 , 18)

ORDER 

PER BIJYANANDA PRUSETH, AM:

These appeals filed by the assessee emanate from the orders passed under section 250 of the Income-tax Act, 1961 (in short, ‘Act’) by the ADDL./JCIT (A)-7, Delhi [in short, “CIT(A)”], both dated 24.09.2025, for the assessment years (AY) 2018-19 and 2019-20. Since the facts are similar and the grounds are identical, with consent of both parties, the appeals were clubbed and heard together and a common order is passed for the sake of convenience and brevity. ITA No.7651/M/2025 for AY 2018-19 is taken as the “lead” case.

2. The grounds of appeal raised by the assessee in ITA No.7651/M/2025 (AY 2018-19) are as under:

“1 Condonation refused without justification: The Ld. CITA erred in refusing to condone the delay in filing the first appeal despite a bona fide and reasonable explana

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