Delay in filing appeal before first appellate authority found 2250 days; condonation denied and appeal dismissed.

When the statutory period to file the first appeal expired before 15.03.2020, the temporary judicial saving for limitation during 15.03.2020-28.02.2022 does not apply; the appeal was therefore measured against the original limitation and found 2250 days late, resulting in dismissal. The appellant's stated causes - erstwhile office bearer non disclosure, election disputes, and alleged chartered accountant non cooperation - lacked detailed, contemporaneous, day by day proof and failed to demonstrate that the delay was beyond control; consequently the tribunal rejected condonation and upheld denial of the claimed exemption under Section 11, dismissing the appeal.

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Issues: (i) Whether the period of delay in filing the appeal before the First Appellate Authority is 2250 days or 1520 days; (ii) Whether the assessee furnished sufficient cause to condone the delay (including reliance on non-cooperation of erstwhile office-bearers and Chartered Accountant) for filing the appeal out of time.

Issue (i): Computation of period of delay (2250 days v. 1520 days).

Analysis: The intimation under Section 143(1) of the Income-tax Act, 1961 was issued on 21.02.2018 and the statutory period to file the first appeal before the CIT(A) commenced from that date, requiring filing on or before 22.03.2018. The Supreme Court decision in Cognizance for Extension of Limitation applies only to rights of appeal or filing whose limitation period fell during 15.03.2020 to 28.02.2022. The assessee's right to appeal expired on 22.03.2018, which is prior to 15.03.2020; therefore the statutory saving of limitation under the cited Supreme Court decision cannot be applied to reduce the delay. On the admitted dates, the appeal filed on 04.06.2024 results in a delay of 2250 days from the expiry of the limitation period.

Conclusion: The period of delay is 2250 days; not 1520 days. (Against the assessee)

Issue (ii): Sufficiency of cause to condone the delay based on disputes among office-bearers and non-cooperation of the Chartered Accountant.

Analysis: The assessee's explanations consisted of (a) erstwhile office-bearers not informing the newly elected governing body about the intimation dated 21.02.2018, (b) disputes concerning elections resolved only by orders in 2022, and (c) alleged non-cooperation of the erstwhile Chartered Accountant and late filing of Form 10B in April 2024. The material on record did not specify dates of meetings, tenures, the timeline of proceedings before the Registrar of Societies, or particulars showing when the newly elected members were legally prevented from assuming office between 2022 and 2024. The affidavits and supporting material did not establish a day-to-day explanation accounting for the entire 2250-day delay, nor did they adequately demonstrate that the matters cited were beyond the assessee's control for the whole period. Reliance on a High Court decision with different facts was not persuasive. Given the abnormal length of delay, the absence of detailed, contemporaneous proof and explanation meant the assessee failed to establish sufficient cause to justify condonation of delay.

Conclusion: The reasons offered do not constitute sufficient cause to condone the 2250-day delay. (Against the assessee)

Final Conclusion: The appeal is invalid for being barred by limitation and the plea for condonation of delay is rejected; the impugned order denying exemption under Section 11 is thereby upheld and the appeal is dismissed.

Ratio Decidendi: Where the statutory limitation to file an appeal expired before 15.03.2020, the temporal saving in the Supreme Court's decision on extension of limitation for the period 15.03.2020 to 28.02.2022 is inapplicable; an appellant bearing an abnormal delay must furnish detailed, day-to-day, contemporaneous explanation showing sufficient cause to justify condonation of such delay.

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