What did the Tribunal hold?

The Tribunal found that the Ld.CIT(A) passed the order without issuing notice to the assessee, violating principles of natural justice. The impugned orders were set aside.

The assessee's appeals were dismissed by the Ld.CIT(A) for non-payment of full tax on returned income without giving an opportunity to be heard. The assessee argued this violated natural justice.

What were the issues?

Whether the Ld.CIT(A) erred in dismissing the appeal without affording the assessee an opportunity of being heard, thereby violating natural justice.

Mannur Whitefield Creators… vs ITO | ITAT Chennai 2026

Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI GAGAN GOYAL

Hearing: 18.06.2026Pronounced: 06.08.2026

आदेश / O R D E R PER ABY T. VARKEY, JM: These are appeals preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeal), Chennai-18 (hereinafter referred to as ‘Ld.CIT(A)’), dated 08.01.2026 for the Assessment Years (hereinafter referred to as ‘AY’) 2023-24 & 2022-23 respectively passed u/s.250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).

ITA No. 2182 & 2186/Chny/2026 (AY 2023-24 & 2022-23) Mannur Whitefield Creators Private Limited :: 2 :: 2. At the outset, the Ld.AR of the assessee brought to our notice that the Ld.CIT(A) has passed the impugned orders without adjudicating the grounds of appeal raised by the assessee by refusing to admit the appeal on the ground that assessee didn’t pay the tax fully on the returned income for both the years. According to the Ld.AR, the Ld.CIT(A) erred in passing the impugned order without giving an opportunity to the assessee to explain, without which the impugned action of the Ld.CIT(A) is in violation of natural justice, therefore, he prays for one more opportunity before the Ld.CIT(A).

According to the Ld.DR admittedly there was short-fall in remitting tax on the returned income and hence, Ld.CIT(A) has rightly dismissed the appeal of the assessee, without admitting the appeals for adjudicating the ground of appeal and hence, he does not want us to interfere with the action of the Ld.CIT(A) for both the years.

Heard broth the parties. Only plea of the assessee is that it should have been heard before the Ld.CIT(A) has passed the impugned order. According to the Ld.AR, even if it is true that there is shortfall in remitting the tax on the returned income, but before the impugned order was passed, assessee ought to have been heard. Since we find that no notice was issued by the Ld.CIT(A) before passing the impugned order, there is per se violation of natural justice and hence, we set aside the impugned

ITA No. 2182 & 2186/Chny/2026 (AY 2023-24 & 2022-23) Mannur Whitefield Creators Private Limited :: 3 :: of the order Ld.CIT(A) and restore the appeal back to the file of the Ld.CIT(A) with a direction to give proper notice and then to pass order in accordance to law.

In the result, the appeals of the assessee are allowed for statistical purposes.

Order pronounced on the 06th day of August 2026, in Chennai.

Sd/- Sd/- (गगन गोयल) (एबी टी. वक�) (ABY T. VARKEY) (GAGAN GOYAL) �या�यक सद�य/JUDICIAL MEMBER लेखा सद�य/ACCOUNTANT MEMBER चे�नई/Chennai, �दनांक/Dated: 06th August, 2026. YS आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF YASHVI Digitally signed by YASHVIR SINGH R SINGH Date: 2026.08.12 16:14:53 +05'30'

MANNUR WHITEFIELD CREATORS PRIVATE LIMITED,CHENNAI vs. INCOME TAX OFFICER, CHENNAI

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