2026 (5) TMI 1196

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....K. Kapoor, CA For the Respondent : Shri Jitender Singh, CIT, DR ORDER PER SUDHIR KUMAR, JUDICIAL MEMBER: This appeal is preferred by the assessee against the order dated 18.11.2025 of the National Faceless Appeal Centre (NFAC) Delhi [hereinafter referred to as "Ld. NFAC)"] against the penalty order dated 10.02.2022 for the assessment year 2018-19 u/s 270A of the Income Tax Act 1961[her....

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....tice under section 143(2) of the Act was issued on 24-12- 2020. After examining the detail furnishing by assessee, the Assessing Officer completed the assessment after making the following additions: (i) Disallowed of late remittance of employee fund Rs. 16,74,760/- (ii) Disallowance of interest expenses on TDS Rs. 50,635/- (iii) Disallowance under section 40(a)(ia) @30 ....

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....l. 6. Ld. AR for the assessee submitted that the appeal was dismissed treating time barred by the first appellate authority. The assessee has moved the application for condonation of delay of 973 days showing the sufficient cause. He prayed that the appeal be admitted for adjudication on merits and delay be condoned. 7. On the other hand, Ld. CIT DR submitted that no sufficient cause has bee....

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....rst time on 15-10-2024 that a notice u/s 221(1) of the Act for the recovery of demands were came in the knowledge. For this reason, the appeal was filed delayed by 973 days. The assessee has shown the sufficient cause not to file the appeal with in time. The Ld. NFAC should have condoned the delay in filing the appeal and should have heard the appeal on merit because the assessee has shown the suf....