ALPESH VALLABHDAS ZINZUWADIA,RAJKOT vs. INCOME TAX OFFICER, WARD-2(1)(2), RAJKOT

ITA 774/RJT/2026Status: DisposedITAT Rajkot14 September 2026AY 2014-154 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeals. It held that the assessee was not given a sufficient opportunity to be heard before the CIT(A), thus violating natural justice principles.

What were the facts?

The assessee filed appeals belatedly. The assessee contended that the CIT(A) order was ex-parte and violated principles of natural justice as they could not represent their case. The Revenue did not object to this contention.

What were the issues?

Whether the ex-parte order passed by the CIT(A) violated the principles of natural justice. Whether the penalty under Section 271(1)(c) can survive when the quantum appeal is restored.

Which sections of the Income-tax Act were involved?

Section 250,Section 147,Section 144B,Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Appellant: Shri Digant Kiyada. Ld. AR
For Respondent: Shri Shishir Kumar, Ld. SR DR
Hearing: 29/07/2026Pronounced: 14/09/2026

Per, Dr. Arjun Lal Saini, AM:

Captioned two appeals filed by the assessee, pertaining to assessment year (AY) 2014-15, are directed against the separate orders passed under section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 25.02.2025 by the National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax (Appeals) [in short ‘Ld.CIT(A)’] which in turn arise out of an assessment order passed by the Assessing Officer (in short ‘AO’) u/s 147 r.w.s. read with section 144B and penalty order u/s. 271(1)C of the

The order continues below.

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