ITAT Condones 2,107-Day Delay, Directs CIT(A) to Reconsider Rs 16.54 Lakh Section 80PA Deduction Claim:

The Income Tax Appellate Tribunal (ITAT), Patna Bench, has granted relief to Jeevika Women Agri Producer Company Ltd. by condoning the delay in filing its appeal and directing the Commissioner of Income Tax (Appeals) to hear the case on merits.

The case relates to the company’s claim for a deduction of Rs. 16.54 lakh under Section 80PA of the Income Tax Act. The company had filed its income tax return declaring a total income of Rs. 7,730. However, the Centralised Processing Centre (CPC) rejected the deduction claim through an intimation dated April 30, 2020, citing issues related to the filing deadline or the conditions applicable to the deduction.

The company challenged the decision before the CIT(A). However, the appeal was dismissed on July 3, 2026, because it was filed with a delay of 2,107 days. The appellate authority held that the company had not provided sufficient reasons to justify the delay.

Before the ITAT, the company’s authorised representative, Rajiv Singh, argued that the delay should not be counted in the usual manner because the company had been pursuing remedies through rectification applications and grievance petitions before the CPC. He submitted that the company’s latest grievance petition was rejected on April 29, 2026, and the appeal was filed on May 16, 2026. The Departmental Representative, Ravi Kant Chowdhary, defended the orders passed by the lower authorities.

After considering both sides, the tribunal held that the company had sufficient cause for not filing the appeal within the prescribed time. It therefore condoned the delay and directed the Commissioner of Income Tax (Appeals) to examine the case on its merits after giving the company a reasonable opportunity to present its arguments.

The tribunal’s decision does not finally approve the company’s deduction claim under Section 80PA. Instead, it allows the company another opportunity to have the claim examined by the appellate authority. The appeal was accordingly partly allowed for statistical purposes.