CIT(A) cannot dismiss Income Tax Appeal on Limitation Grounds after Condoning Delay: ITAT

The Income Tax Appellate Tribunal (ITAT) recently ruled on a matter concerning the dismissal of an income tax appeal by the Commissioner of Income Tax (Appeals) on grounds of limitation. The case highlighted that once the delay in filing an appeal has been condoned by the CIT(A), the appeal cannot subsequently be dismissed on the grounds of limitation. In this instance, the CIT(A) had previously accepted the late filing of the appeal but later dismissed it on the basis that it was still beyond the permissible period. The ITAT found this approach incorrect, emphasizing that the condonation of delay is a one-time remedy that allows the appeal to proceed despite being filed late. This decision reaffirms the principle that procedural lapses should not undermine the substantive rights of taxpayers, reinforcing the need for fair treatment in appellate proceedings.