In a significant ruling reinforcing a justice-oriented approach, the Telangana High Court condoned a delay of 202 days in filing an appeal before the Income Tax Appellate Tribunal (ITAT), acknowledging the severe impact of the COVID-19 pandemic on business operations.
The decision, reported as [2026] 183 taxmann.com 460 (Telangana) dated 29 January 2026, highlights the judiciary’s pragmatic stance in matters involving procedural delays caused by extraordinary circumstances.
Background of the Case
The assessee had filed an appeal before the ITAT challenging an adverse tax order. However, the appeal was delayed by 202 days. The Tribunal dismissed the appeal strictly on the ground of limitation, without examining the case on merits.
Aggrieved by the dismissal, the assessee approached the Telangana High Court, contending that the delay was neither deliberate nor negligent but was caused due to the unprecedented disruption created by the COVID-19 pandemic. The assessee submitted that its business operations had come to a virtual standstill during the relevant period, making it practically impossible to pursue legal remedies within the prescribed timeline.
Legal Issue
The primary issue before the Court was:
Whether a delay of 202 days in filing an appeal before the ITAT should be condoned when the assessee demonstrates that the delay was caused due to COVID-19-related business disruption?
High Court’s Observations
The High Court took judicial notice of the widespread economic and administrative disruptions caused by the pandemic. It emphasized that courts must adopt a liberal and justice-oriented approach while dealing with condonation of delay applications, particularly where sufficient cause is shown.
The Court observed that procedural laws are meant to advance justice, not to defeat it. When the delay is attributable to circumstances beyond the control of the litigant, technicalities should not override substantive justice.
Ruling of the Court
The Telangana High Court held that:
- The delay was bona fide and sufficiently explained.
- The impact of COVID-19 constituted a valid and reasonable cause.
- The matter deserved to be adjudicated on merits rather than dismissed on technical grounds.
Accordingly, the Court:
- Condoned the delay of 202 days.
- Directed payment of ₹15,000 as costs.
- Ordered restoration of the appeal before the Tribunal for decision on merits.
Significance of the Judgment
This ruling reiterates that:
- COVID-19-related disruptions can qualify as “sufficient cause” under limitation law.
- Courts prefer adjudication on merits over dismissal based on technicalities.
- While delays may be condoned, courts can impose costs to balance procedural discipline.
The judgment provides relief to taxpayers whose legal proceedings were adversely affected during the pandemic period and reinforces the principle that justice should not be sacrificed at the altar of procedural rigidity.