ALAKAPURI SAI MANDIRAM TRUST,HYDERABAD V. ITO., WARD-11(1), HYDERABAD

ITA 1192/HYD/2025

AI Insights

The case involves the Alakapuri Sai Mandiram Trust, which appealed against the order of the Learned First Appellate Authority (LFAA) that dismissed their appeal due to a significant delay in filing. The Trust had initially filed an appeal against the processing of their income tax return by the Centralized Processing Centre (CPC), which was processed under section 143(1) of the Income Tax Act, 1961. The LFAA dismissed their appeal in limine as it was filed 1,817 days late, and the Trust failed to provide satisfactory reasons for such a delay. The Tribunal, after hearing the arguments, agreed with the LFAA's decision and dismissed the Trust's appeal, emphasizing the lack of reasonable cause for the delay.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 783595 (ITAT-HYDERABAD)
• Duration Of Justice: 3 month(s) 16 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 07-11-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: SMC
• Assessment Year: 2018-2019
• Appeal Filed On: 22-07-2025
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Assessee Lawyers: A SRINIVAS
• Keywords: Reasonable cause

Judgement Text

" ITA No 1192 of 2025 Alkapuri Sai Mandiram Trust Hyderabad Page 1 of 4 आयकर अपीलȣय अͬधकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ SM ‘ Bench, Hyderabad ŵी रिवश सूद,Ɋाियक सद˟ एवं ŵी मधुसूदन साविड़या लेखा सद˟ समƗ | Before Shri Ravish Sood, Judicial Member A N D Shri Madhusudan Sawdia, Accountant Member आ.अपी.सं /ITA No.1192/Hyd/2025 (िनधाŊरण वषŊ/Assessment Year: 2018-19) Alakapuri Sai Mandiram Trust, Hyderabad PAN:AADTA7032K Vs. Income Tax Officer Ward 11(1) Hyderabad (Appellant) (Respondent) िनधाŊįरती Ȫारा/Assessee by: Shri A Srinivas, CA राज̾ व Ȫारा/Revenue by:: Shri V. Ravish Bhatt, Sr.DR सुनवाई की तारीख/Date of hearing: 30/10/2025 घोषणा की तारीख/Pronouncement: 07/11/2025 आदेश/ORDER Per Madhusudan Sawdia, A.M.: This appeal is filed by Alakapuri Sai Mandiram Trust, Hyderabad (“the assessee”), feeling aggrieved by the order passed by the Learned Addl/JCIT(A)-2, Chandigarh, (“Ld. First Appellate Authority)”) dated 29/04/2025 for the A.Y. 2018-19. 2. The assessee has raised the following grounds of appeal: Printed from counselvise.com ITA No 1192 of 2025 Alkapuri Sai Mandiram Trust Hyderabad Page 2 of 4 3. The brief facts of the case are that the assessee is a trust which had filed an appeal before the Ld. First Appellate Authority against the processing of return of income made by the Centralized Processing Centre (“CPC”) under section 143(1) of the Income Tax Act, 1961 (“the Act”) dated 26.09.2019. However, there was a delay of 1,817 days in filing the appeal before the Ld. First Appellate Authority. The Ld. First Appellate Authority, after considering the submissions of the assessee, did not find the reasons for such an inordinate delay to be satisfactory and accordingly declined to condone the delay. Consequently, the appeal of the assessee was dismissed by the Ld. First Appellate Authority in limine as being barred by limitation. 4. Aggrieved by the order of the Ld. First Appellate Authority), the assessee has preferred the present appeal before this Tribunal. We have heard the rival contention and carefully considered the material available on record. It is observed that there was an inordinate delay of 1,817 days in filing the appeal Printed from counselvise.com ITA No 1192 of 2025 Alkapuri Sai Mandiram Trust Hyderabad Page 3 of 4 before the Ld. First Appellate Authority. Despite such a long delay, the assessee has not explained any reasonable cause for the delay before the Ld. First Appellate Authority. The power to condone delay under section 249(3) of the Act is discretionary on the part of the Ld. First Appellate Authority and can be exercised only when the assessee shows sufficient and reasonable cause for not filing the appeal within the prescribed time. In the instant case, as no such reasonable cause has been demonstrated by the assessee before the Ld. First Appellate Authority, the Ld. First Appellate Authority did not condone the delay and consequently, dismissed the appeal of the assessee. The assessee has also failed to demonstrate any reasonable cause qua, the delay in filing the appeal before the Ld. First Appellate Authority, therefore, we do not find any infirmity in the action of the Ld. First Appellate Authority in refusing to condone the delay. Accordingly, we uphold the order of the Ld. First Appellate Authority dismissing the appeal of the assessee as barred by limitation. Consequently, the appeal filed by the assessee before us also fails. 5. In the result, the appeal filed by the assessee is dismissed. Order pronounced in the Open Court on 7th November, 2025. Sd/- Sd/- (RAVISH SOOD) JUDICIAL MEMBER (MADHUSUDAN SAWDIA) ACCOUNTANT MEMBER Hyderabad, dated 7th November, 2025 Vinodan/sps Printed from counselvise.com ITA No 1192 of 2025 Alkapuri Sai Mandiram Trust Hyderabad Page 4 of 4 Copy to: S.No Addresses 1 Alakapuri Sai Mandiram Trust, Plot No.171, Survey No.9/1/F Alkapuri, Hyderabad 500035 2 Income Tax Officer Ward 11(1) Signature Towers, Kothaguda, Opp: Botanical Gardens, Hyderabad 500084 3 Pr. CIT - Hyderabad 4 DR, ITAT Hyderabad Benches 5 Guard File By Order Printed from counselvise.com "