The Delhi Income Tax Appellate Tribunal (ITAT) has provided significant relief to a taxpayer who missed income tax notices due to address changes. According to the tribunal's order pronounced on 4 August 2026 by Judicial Member Madhumita Roy in ITA No. 3272/Del/2026, the ITAT condoned a 2,073-day delay in filing an appeal and deleted an ₹11 lakh tax addition after hearing the taxpayer's explanation. The case involved Hira Ballabh Khulbe, whose assessment for assessment year 2012-13 was reopened after tax authorities received information about the cash deposit in a joint account.
The Delhi ITAT has provided significant relief to a taxpayer who missed income tax notices due to address changes. According to the tribunal's order, Khulbe told the tribunal that he had shifted from Faridabad in December 2010 and that no member of his family was living at the old address. As a result, he said he never received the notices and was unaware of the reassessment proceedings. The tribunal noted that this explanation was supported by an affidavit and other relevant documents, leading to the condonation of the substantial delay in filing the appeal.
According to the tribunal order, the Assessing Officer completed the assessment ex parte under sections 147 and 144 of the Income-tax Act, treating the entire ₹11 lakh cash deposit as income. This resulted in a tax demand of ₹5.06 lakh. Khulbe said he came to know about the demand only in AY 2023-24 through his chartered accountant and subsequently filed an appeal before the National Faceless Appeal Centre on 9 September 2025, along with an application seeking condonation of the 2,073-day delay.
As reported by the tribunal, Khulbe maintained that the ₹11 lakh deposited in the joint bank account was not unexplained income. According to his explanation, ₹8 lakh represented proceeds from the sale of a residential property, while the remaining ₹3 lakh came from past savings. The tribunal noted that this explanation was supported by an affidavit and other relevant documents, leading to the deletion of the tax addition. The CIT(A) had dismissed the appeal on the ground that it was filed beyond the prescribed limitation period, but the ITAT took a different view and considered the taxpayer's old age and relatively small tax demand while disposing of the matter.
According to the tribunal's ruling, the case does not mean that every cash deposit will automatically be accepted as explained or that taxpayers can routinely file appeals years after the deadline. The case turned on its own facts, with the taxpayer able to explain why he had not received notices and supported his explanation with an affidavit. The ruling highlights two practical points for taxpayers: an old address can create serious problems if income-tax notices are sent there, and documentation showing the source of a large cash deposit can become crucial if the tax department later questions it. The case emphasizes that the tribunal did not treat the long delay alone as sufficient reason to shut the door on the taxpayer, considering the explanation that the taxpayer had moved away from the address to which the notices were sent.
