CRISIL LIMITED ,MUMBAI vs. DCIT, CIRCLE 15(1)(2), MUMBAI

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ITA 6600/MUM/2025Status: DisposedITAT Mumbai12 December 2025AY 2022-23Bench: SHRI VIKRAM SINGH YADAV (Accountant Member), SHRI SANDEEP SINGH KARHAIL (Judicial Member)4 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal set aside the order of the CIT(A) and remanded the matter back for fresh adjudication. The CIT(A) was directed to provide a reasonable opportunity to the assessee to present its case.

What were the facts?

The assessee's appeal before the CIT(A) was dismissed. The assessee contended that the CIT(A) passed the order without providing a fair opportunity of being heard, as adjournments were sought for compiling submissions but the order was passed on the same day.

What were the issues?

Whether the CIT(A) provided a fair opportunity of hearing to the assessee before passing the impugned order.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI “I” BENCH : MUMBAI

Before: SHRI VIKRAM SINGH YADAV & SHRI SANDEEP SINGH KARHAIL

Assessment Year : 2022-23 Crisil Limited, Deputy Commissioner of Lightbridge IT Park, Income Tax, Crisil Limited, vs. Circle-15(1)(2), Saki Vihar Road, Aayakar Bhavan, Andheri East, M.K.Road, Mumbai-400072. Mumbai-400020. PAN : AAACT3151E (Appellant) (Respondent) For Assessee : Shri Dhanesh Bafna/Amol Mahajan For Revenue : Shri Satya Pal Kumar, CIT-DR Date of Hearing : 09-12-2025 Date of Pronouncement : 12-12-2025 O R D E R PER VIKRAM SINGH YADAV, A.M : This is an appeal filed by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi [„Ld.CIT(A)‟], dated 14-08-2025, pertaining to Assessment Year (AY) 2022-23.

2.

Briefly stated, facts of the case are that assessment in this case was completed u/s. 143(3) r.w.s. 144B of the Income Tax Act, 1961 („the Act‟), vide order dt. 27-02-2025. The assessee thereafter carried the matter in appeal before the Ld.CIT(A), who has since dismissed the appeal and against the said order, the assessee is in appeal before us.

3.

The limited submission raised by the Ld.AR on behalf of the assessee was that the Ld.CIT(A) has passed the impugned order, without providing a fair opportunity of being heard to the assessee and it was accordingly submitted that the matter may be set aside to the file of the Ld.CIT(A) and the assessee may be allowed one more opportunity. In this regard, our reference was drawn to the impugned order, wherein there is reference to notices issued by the Ld.CIT(A) and in respect of which the assessee has sought adjournment for the reason that it is in the process of compiling the necessary submissions and thereafter, the matter was listed for hearing on 14-08-2025 and there again, the assessee has sought certain further time and it was submitted that without adjourning the matter any further, the Ld.CIT(A) has passed the impugned order on 14-08-2025 itself. It was accordingly submitted that the assessee deserves one more opportunity to put forward its submissions and file necessary documentation in support of various grounds of appeal and the matter may be accordingly set aside to the file of the Ld. CIT(A).

4.

The Ld. DR has been heard, who has not raised any specific objection, where the matter is set aside to the file of the Ld.CIT(A).

5.

Considering the limited prayer raised by the Ld.AR on behalf of the assessee which has not been contested by the Ld.DR, the matter is set- aside to the file of Ld.CIT(A) for deciding the same afresh as per law, after providing reasonable opportunity to the assessee.

6.

Needless to say, the assessee shall attend to the proceedings and file necessary submissions/documentation as so advised and shall co-operate with the Ld.CIT(A) for expeditious disposal of the matter under appeal.

7.

In the result, the appeal filed by the assessee is allowed for statistical purposes.

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