Delay Should Be Viewed Pragmatically, Not Pedantically: ITAT Condones Up to 884 Days’ Delay for Co-op Society to File Appeal

The Income Tax Appellate Tribunal (ITAT) has adopted a remarkably liberal approach in condoning a substantial delay of 884 days in the filing of appeals by a cooperative society. The tribunal explicitly emphasized its preference for a pragmatic and realistic perspective over a strictly pedantic adherence to technical procedural lapses. In reaching its decision, the ITAT took into consideration the genuine difficulties and extenuating circumstances faced by the cooperative society, while also imposing a nominal cost on the society as a symbolic measure for the significant delay.