आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ B ‘ Bench, Hyderabad (cid:373)ी रिवश सूद,(cid:586)ाियक सद(cid:735) एव ं(cid:373)ी मधुसूदन साविड़या लेखा सद(cid:735) सम(cid:407) |

Before Shri Ravish Sood, Judicial Member A N D Shri Madhusudan Sawdia, Accountant Member Appeal in ITA Assessee Revenue A.Y

1317/Hyd/2025 Smt. Lingamgunta Income Tax Officer 2015-16 Adilaxmi, Secunderabad Ward 10 (1) PAN:AMNPL4940M Hyderabad

915/Hyd/2025 Shri Raghu Alekh Barli Dy. CIT 2018-19 Hyderabad Circle 6(1)

PAN:AHJPA1085F Hyderabad

1487/Hyd/2025 Sanzyme Private Ltd Dy. CIT 2019-20 Hyderabad Circle 3(1)

PAN:AAACU2692R Hyderabad

1606/Hyd/2025 Shri Bikaram Income Tax Officer 2018-19 Pushpender, Hyderabad Ward 9(1)

PAN: CEBPP4471F Hyderabad िनधा१ौरती (cid:554)ारा/Assessee by: Advocates Shri S. Rama Rao &

Sashank Dundu and C.A. Kumar Pal Tated राज(cid:830) व (cid:554)ारा/Revenue by:: Shri Waseem UR Rahman, Sr. DR सुनवाई की तारीख/Date of hearing: 03/12/2025 & 04/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025 आदेश/ORDER Per Madhusudan Sawdia, A.M.:

These four appeals are filed by the above assessees feeling aggrieved by the separate orders passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”) for the A.Ys 2015-16, 2018-19 and 2019-20 respectively. Since common issues are involved in all these four appeals, for the sake of convenience, these were heard together and are being disposed of by this common consolidated order.

ITA No.1317/Hyd/2025:

2. At the outset, we observed that there is a delay of 21 days in filing of the appeal before the Tribunal. The assessee has filed a condonation petition accompanied by a copy of affidavit explaining the reasons which led to the delay in filing the appeal. The Learned Authorized Representative (“Ld. AR”) submitted that the order of the Ld. CIT(A) was passed on 27.05.2025. Accordingly, the assessee was required to file the appeal before this Tribunal on or before 31.07.2025. However, the appeal was filed on 21.08.2025, resulting in a delay of 21 days. The Ld. AR submitted that the assessee was suffering from dengue fever with effect from 25.07.2025. Due to the said illness, the assessee was under continuous medical supervision and was advised three weeks of complete rest. In support of this contention, a medical certificate issued by the treating hospital has been placed on record. It was therefore submitted that the delay was neither intentional nor deliberate, and there was no element of mala fide or negligence on the part of the assessee. The Ld. AR accordingly prayed that the delay be condoned and the appeal be admitted for adjudication on merits.

3. Per contra, the Learned Departmental Representative (“Ld. DR”) did not raise any serious objection to the condonation of delay.

4. We have carefully considered the submissions of both parties and perused the material placed on record. On perusal of the medical certificate and the affidavit filed by the assessee, we are satisfied that the assessee was prevented by reasonable and sufficient cause from filing the appeal within the prescribed period of limitation. In the absence of any mala fide intention or deliberate inaction and keeping in view the principles laid down by the Hon’ble Supreme Court that substantial justice should prevail over technical considerations, we are inclined to condone the delay of 21 days. Accordingly, the delay in filing the appeal is hereby condoned, and the appeal is admitted for adjudication on merits.

5. The assessee has raised the following grounds of appeal:

6. The brief facts of the case are that the assessee had filed an appeal before the Ld. CIT(A) against the order of the Learned Assessing Officer (“Ld. AO”) passed for Assessment Year 2015-16 under Section 147 r.w.s. 144 of the Income Tax Act, 1961(“the Act”), dated 22.02.2024. The Ld. CIT(A) dismissed the appeal of the assessee.

7. Aggrieved by the order of the Ld. CIT(A), the ass