Pandemic-related delay in tax appeals may warrant liberal condonation where lockdown disruption and bona fide sufficient cause are demonstrated.

Pandemic-related disruption may justify condoning delay in filing an appeal against an intimation under Section 143(1) where the assessee did not notice electronic communications during lockdown, office operations had collapsed, and movement was restricted. The notes emphasise that limitation exclusions for judicial and quasi-judicial proceedings affect delay computation, while affidavits and prompt action after discovering a demand through refund adjustment may establish sufficient cause and bona fides. Where an appeal was rejected solely on limitation without examining additions or exemption denial, the matter may be restored for determination on merits.

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Issues: Whether the delay in filing the first appeal against the intimation under Section 143(1) of the Income-tax Act, 1961 was liable to be condoned, and whether the matter should be restored for decision on merits.

Analysis: The delay arose from the assessee's failure to notice the intimation and related electronic communications during the Covid-19 lockdown period, when office functioning had collapsed and movement of staff and trustees was severely restricted. The limitation for filing the appeal expired during the lockdown phase. The explanation was supported by affidavit and the subsequent conduct showed prompt action once the assessee became aware of the demand through refund adjustment. The exclusion of limitation directed for judicial and quasi-judicial proceedings during the pandemic materially affected the computation of delay, and the residual delay stood reasonably explained. In this background, a strict rejection of condonation was inconsistent with the principle that limitation provisions should be applied liberally where sufficient cause and bona fides are established. Since the appellate authority had dismissed the appeal only on limitation and had not examined the additions or denial of exemption on merits, restoration was required.

Conclusion: The delay was condoned in favour of the assessee, and the matter was restored to the appellate authority for fresh adjudication on merits in accordance with law.

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