CONNECCT MY TRIP,COIMBATORE vs. ITO, NCW-4(3), COIMBATORE
What did the Tribunal hold?
The Tribunal noted that the assessee had not complied with statutory notices before the AO and that the CIT(A) had not granted reasonable time for compliance. Therefore, the matter was remanded to the AO for fresh consideration.
What were the facts?
The assessee's appeal was against the order of the CIT(A). The assessee argued that no opportunity was given by the authorities below and requested a remand. The CIT(A) also allegedly did not provide reasonable time for compliance.
What were the issues?
Whether the assessee was provided with adequate opportunity to present its case before the lower authorities, and if not, whether the matter should be remanded.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Before: SHRI S.S. VISWANETHRA RAVI & SHRI S.R. RAGHUNATHA
आयकर अपीलीय अिधकरण, ’ ए ’ �ायपीठ, चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI �ी एस.एस. िव�ने� रिव, �ाियक सद� एवं �ी एस.आर. रघुनाथा, लेखा सद� के सम$ BEFORE SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBER & SHRI S.R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./I.T.A. No. 3381/Chny/2026 िनधा%रण वष%/Assessment Year: 2020-21 Connect My Trip, Vs. Income Tax Officer, 11/59A Sri Guruvayarappan Vilas, Non-Corporate Ward -4(3), Thiruvalluvar Street, Coimbatore. G.N. Mills Post, Coimbatore – 641 029. [PAN: AAIFC-9319-C] (अपीलाथ'/Appellant) (()थ'/Respondent) अपीलाथ' की ओर से / Appellant by : Mr. N. Arjun Raj, Advocate ()थ' की ओर से/Respondent by : Ms. R. Anita, CIT सुनवाई की तारीख/ Date of hearing : 18.08.2026 घोषणा की तारीख /Date of Pronouncement : 20.08.2026 आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:
This appeal filed by the assessee is directed against the order dated 16.04.2026 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2020-21.
:-2-: ITA No: 3381/Chny/2026
The ld.AR, Mr. N. Arjun Raj, Advocate, submits that there was no
opportunity for the assessee before both the authorities below and
prayed to remand the matter to the file of the AO. Further, he drew our
attention to the page no.4 of the impugned order and argued that there
was no reasonable time given by the ld.CIT(A) to the assessee to
prosecute its case. He submits that the assessee is ready to furnish all
the details before the AO if this Tribunal give opportunity to the
assessee.
The ld.DR, Ms. R. Anita, CIT, vehemently opposed the same and
relied on the order of the ld.CIT(A).
Upon hearing both the parties, we note that the AO recorded the
details of opportunities given to assessee in page no.4 of the
assessment order, wherein the assessee offered response only with
reference to filing of ITR in response to notice u/s. 148 of the Act and no
compliances were made in respect of statutory notices u/s. 143(2) of the Act and 142(1) of the Act. Therefore, it is clear that there was no
compliance before the AO in prosecuting its case. Further, as rightly
pointed by the ld.AR that the ld.CIT(A) has given first notice on
:-3-: ITA No: 3381/Chny/2026
09.03.2026 intimating the date of hearing on 16.03.2026, wherein it is noted that there was no reasonable time given to assessee for its compliance, likewise on 17.03.2026 and 24.03.2026, we find no reasonable time was granted by the ld.CIT(A). Therefore, the arguments of the ld.DR are not acceptable in opposing to remand the matter to the file of the AO. Therefore, in the interest of justice and taking into account facts and circumstances of the case, we deem it proper to remand the matter to the file of the AO. The assessee is liberty to file evidences, if any, in support of its claim. Thus, order of the ld.CIT(A) is set aside and grounds raised by the assessee are allowed for statistical purposes.
In the result, appeal filed by the assessee is allowed for statistical purposes.
Order pronounced on 20th August, 2026 at Chennai.
Sd/- Sd/- (S.R. RAGHUNATHA) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER Chennai, Dated: 20.08.2026 JPV आदेश की (ितिलिप अ.ेिषत/Copy to: 1. अपीलाथ'/Appellant, 2.()थ'/ Respondent,
:-4-: ITA No: 3381/Chny/2026
आयकर आयु//CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय (ितिनिध/DR & 5. गाड% फाईल/GF
Digitally signed by PRASANNA PRASANNA VANI JETTY VANI JETTY Date: 2026.08.24 12:00:04 +05'30'
More judgments on Section 148
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
- Adj Agri International LLP, Rajkot vs The Income Tax Officer, Ward-1(1)(1), RajkotITA 1198/RJT/2026[2018-19]Status: Disposed21 Oct 2026AY 2018-19
Recent GST High Court judgments
Search GST case law →- Dillip Kumar Behera vs. The Assistant Commissioner Of State Tax, Mayurbhanj CircleOrissa · 15 Oct 2026
- M/S. Kalinga Paper Mart, Sundergarh vs. Commissioner Of CT And GST, CuttackOrissa · 15 Oct 2026
- Kabita Nayak vs. Chief Commissioner, CGST, Central Excise And Customs, KhurdaOrissa · 15 Oct 2026
- Swastika Ingot PVT.LTD, Sundargarh vs. The Addl Commissioner, GST And Central Excise, BhubaneswarOrissa · 15 Oct 2026
- M/S Basudev Logistics, Jagatsinghpur vs. Principal Commissioner, CGST And Central Excise, BhubaneswarOrissa · 15 Oct 2026