‘No person will derive any Undue Benefit by not preferring Appeal against any Assessment order passed under Act’: ITAT condones 2564-day delay

The ITAT condoned a delay of 2,564 days in filing an appeal against an assessment order, emphasizing that no undue benefit arises from not preferring an appeal. The taxpayer argued that the substantial delay was due to circumstances beyond their control and did not indicate negligence or malintent. The tribunal acknowledged the taxpayer’s explanations and directed the assessing authorities to reconsider the case. This judgment underscores the principle that justice should not be denied on technicalities, provided the applicant demonstrates genuine reasons for non-compliance. Legal experts view this as reinforcing fair adjudication processes, balancing procedural compliance with substantive justice. The decision sets a precedent encouraging taxpayers facing extraordinary circumstances to seek remedies without fear of procedural disqualification. It also emphasizes the discretionary powers of the judiciary to ensure equitable outcomes.