IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE – PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER Assessment Year : 2021-22 Senior Sub-Registrar, Malleshwaram, Office of the Sr.Sub Registrar, The Joint / Additional No. 11 & 12, 1^st and 2^nd Director of Income Tax Main Road (I & CI), Palace Guttahalli, Bangalore.

Malleshwaram, Vs.

Bangalore North, Bangalore – 560 003.

PAN: BLRS32826D APPELLANT RESPONDENT Assessee by : Shri Suresh Rao, CA Revenue by : Shri Subramanian .S, JCIT-DR Date of Hearing : 12-02-2026 Date of Pronouncement : 19-02-2026

ORDER

PER SOUNDARARAJAN K., JUDICIAL MEMBER This is an appeal filed by the Appellant challenging the order of the NFAC, Delhi dated 31/08/2025 in respect of the A.Y. 2021-22 and raised the following grounds:

“1) The order of the Ld CIT(A) NFAC Delhi is arbitrary, against the provisions of law, Principles of Natural Justice and contrary to the facts of the case and is therefore unsustainable.

2) The Ld CIT(A) erred in not condoning the delay in filing the appeal which was due to genuine and bona fide reasons against an arbitrary Penalty Order.

3) The Ld CIT(A) erred in dismissing the appeal in limine w