PSP TRADING PVT. LTD.,PATNA vs. ACIT, CIRCLE-1, PATNA, PATNA

ITA 15/PAT/2026Status: DisposedITAT Patna10 August 2026AY 2019-206 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to the assessee's mistaken belief of filing a revision petition. The matter was remitted back to the Assessing Officer for fresh consideration after providing the assessee an opportunity to be heard and substantiate its case.

What were the facts?

The assessee failed to file a return of income for AY 2019-20 and did not comply with notices issued under section 148/147. The assessment was completed ex-parte at Rs. 20,71,794/- based on information from a search operation on the Shah group, with whom the assessee had cash transactions.

What were the issues?

Whether the delay in filing the appeal before the CIT(A) should be condoned, and if the ex-parte assessment order should be set aside for fresh adjudication.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 249(2),Section 264

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA BENCH, PATNA

For Appellant: Shri Manish Rastogi & Anup Kumar, Adv
For Respondent: Shri Ravi Kant Chowdhary, Sr. DR
Hearing: 28.07.2026Pronounced: 10.08.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

This is an appeal filed by the assessee against the order passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “the Ld. CIT(A)] dated 15.12.2025, DIN & order No. ITBA/NFAC/S/250/2025- 26/1083701067(1) on the following grounds of appeal:

2

2.

Briefly stated the facts of the case are that as per the information received by the Income Tax Department, it was noticed that the assessee did not file return of income for the assessment year 2019-20 and has entered into cash transaction of Rs.20

The order continues below.

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