ITAT Holds Bureaucratic Delays Cannot Constitute Sufficient Cause:

The ITAT Delhi rejects routine explanation for Condonation holding Supreme Court rulings on Limitation apply equally to Revenue.
ITAT Dismisses Revenue’s Appeal for Delay

The Income Tax Appellate Tribunal (ITAT), Delhi dismissed the appeal filed by the Revenue against the order of the CIT(A) dated December 19, 2025, for Assessment Year 2011-12. The assessee, Urvashi Developers and Builders Pvt. Ltd., had also filed cross-objections in the Revenue's appeal.
At the outset, the Tribunal noted that the Revenue's appeal was delayed by 649 days. While considering the Department's application seeking condonation of delay, the Tribunal observed that the reasons furnished by the Revenue were routine and stereotyped in nature and did not establish any legally acceptable ground for condoning such an inordinate delay.
The Tribunal referred to the Supreme Court's decision in various cases. Further, the Tribunal took note of the Supreme Court's recent decision in State of Odisha Vs Managing Committee of Namatara Girls High School Case where it was held that there must be a distinction between a genuine explanation and a mere excuse for delay.
Applying the principles laid down by the Supreme Court, the Tribunal held that the Revenue had failed to establish any sufficient cause for the delay of 649 days in filing the appeal. Accordingly, the Revenue's appeal was dismissed on the ground of limitation. Accordingly, the cross-objections were also dismissed as infructuous without any independent adjudication of the merits of the Section 153C challenge.
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Saima
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Delhi, Delhi, India
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