Tax Tribunal allows appeal for 2020-21, directs disallowance deletion by CPC. Condoned delay for 2017-18 due to Covid.

The Tribunal allowed the appeal for the assessment year 2020-21, directing the deletion of disallowances made by the Centralized Processing Centre (CPC) under the Income Tax Act. For the assessment year 2017-18, the Tribunal condoned the delay in filing the appeal due to the Covid Pandemic and remanded the case back to the Commissioner for a decision on merits. The appeal for 2017-18 was treated as allowed for statistical purposes.

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Issues involved: Appeal against order passed by Commissioner of Income Tax (Appeals) for assessment years 2017-18 & 2020-21; Disallowances made by Centralized Processing Centre (CPC) under various sections of the Income Tax Act, 1961; Delay in filing appeal for assessment year 2017-18 due to Covid Pandemic.

For Assessment Year 2020-21:
The assessee, engaged in manufacturing steel doors, appealed against disallowances made by CPC under different sections of the Income Tax Act. The first appellate authority's order lacked reasoning and discussion on the additions made. The Tribunal found the order unsatisfactory and noted that the assessee had already self-disallowed the amounts in question. The Tribunal directed the Assessing Officer to verify the self-disallowances and delete the fresh disallowances made by CPC, concluding in favor of the assessee.

For Assessment Year 2017-18:
The delay in filing the appeal was attributed to the Covid Pandemic causing disruption in the assessee's activities. The Commissioner refused to condone the delay, citing the assessee's ability to appeal before the pandemic. However, the Tribunal observed that the assessee had actively pursued correction of demand before the pandemic, which was evident from a rectification request submitted in 2019. Considering the circumstances and pursuit of remedy, the Tribunal decided to condone the delay and remanded the appeal back to the Commissioner for a decision on merits.

Conclusion:
The Tribunal allowed the appeal for the assessment year 2020-21 and treated the appeal for the assessment year 2017-18 as allowed for statistical purposes. The decision was made to delete the disallowances for the assessment year 2020-21 and to remand the appeal for the assessment year 2017-18 back to the Commissioner for further consideration.

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