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2026 Supreme(Online)(ITAT) 6306

INCOME TAX APPELLATE TRIBUNAL (DEHRADUN BENCH)
Yogesh Kumar, Judicial Member, Manish Agarwal, Accountant Member
Pal Mineral Industries (P) – Appellant
Versus
DCIT/ACIT, Central Circle – Respondent


Advocates:
For the Appellants/Petitioners: Shri Kalrav Mehrotra, Adv., Shri Shubham Bansal, Adv.
For the Respondents: Ms. Poonam Sharma, CIT DR

Table of Content
1. delay in appeal condoned for genuine cause. (Para 2)
2. additional legal grounds admitted. (Para 3 , 4)
3. defective satisfaction invalidates s.153c proceedings. (Para 5 , 6 , 7 , 8 , 9 , 10)
4. appeals allowed; assessments quashed. (Para 11 , 12)

ORDER

PER BENCH

The captioned appeals are filed by assessee against the orders, both dated 29.03.2025 by Ld. Commissioner of Income Tax (A), Lucknow-3 [“Ld. CIT(A)”] passed u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment order, both dated 29.12.2019 passed u/s 143(3) r.w.s. 153C of the Act pertaining to Assessment Year 2014-15 and 2013-14 respectively.

2. Both appeals filed delayed by 08 days for which an affidavit is filed explaining the circumstances for the delay. It is stated that the assessee and its counsel are placed at two different cities therefore, the appeal could not be filed with the limitation period. We find that the reasons stated is having genuine and reasonable cause thus, the delay in filing the appeal by 08 days is condoned.

3. Ld.AR for the assessee filed an application for admission of additional grounds of appeal and contended containing that these additional grounds of appeal ar

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