PUNJAB NATIONAL BANK,DHALPUR KULLU vs. ITO TDS, DHALPUR KULLU

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ITA 204/CHANDI/2026Status: DisposedITAT Chandigarh04 August 2026AY 2014-152 pages
AI SummaryWithdrawn

What did the Tribunal hold?

The Tribunal granted permission to the appellant to withdraw the appeal as it had become infructuous. The appeal was dismissed as withdrawn.

What were the facts?

The appellant filed an appeal before the ITAT due to an inadvertent clerical error regarding incorrect appeal/assessment particulars. The appellant subsequently filed a correct appeal before the CIT(A), which was allowed in their favour.

What were the issues?

Whether the appeal filed before the ITAT is infructuous due to a subsequent favorable order from the CIT(A) on a correctly filed appeal.

Which sections of the Income-tax Act were involved?

Section 201

AI-generated summary — verify with the full judgment below

आयकर अपीलीय अिधकरण,च�ीगढ़ �ायपीठ “बी” , च�ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “B”, CHANDIGARH HEARING THROUGH: PHYSICAL MODE �ी लिलत कुमार, �ाियक सद� एवं �ी िवजय वमा� , लेखा सद� BEFORE: SHRI. LALIET KUMAR, JM & SHRI. VIJAY VARMA, AM आयकर अपील सं./ ITA No. 204 /Chd/ 2026 िनधा�रण वष� / Assessment Year : 2014-15 Punjab National Bank बनाम The ITO Kullu, Himachal Pradesh TDS, Kullu, Himachal Pradesh �ायी लेखा सं./PAN NO: PTLP11671C अपीलाथ�/Appellant ��थ�/Respondent िनधा�रती की ओर से/Assessee by : Shri Munish Sood, Advocate राज� की ओर से/ Revenue by : Dr. Ranjit Kaur, Addl. CIT, Sr. DR सुनवाई की तारीख/Date of Hearing : 03/08/2026 उदघोषणा की तारीख/Date of Pronouncement : 04/08/2026 आदेश/Order PER VIJAY VARMA, A.M: This is an appeal filed by the Appellant against the order of the Ld. CIT, Appeal, ADDL/JCIT(A) Panchkula, dt. 05/01/2026 for the Assessment Year 2014-15 in appeal No. NFAC/2012-13/10064426.

2.

In this appeal the appellant has raised the following grounds of appeal: 1. That the order of the Ld. CIT is unjustified and against the law. 2. That the Ld. CIT was not justified in upholding the demand of Rs. 3,09,222/- as there are several case laws strengthening our case that the bank cannot be merely treated as assesse in default simply because the interest amount exceeds the basic exemption limit. 3. That the Ld. CIT is not justified in imposing a interest of Rs. 2,68,204/- on the above even when the bank was never in assessee in default within the meaning of section 201 of the Income Tax Act. 4. That the order of the Ld. AO was ethical and uncalled for and need to be quashed. 5. That any other ground of appeal raised at the time of the hearing.

3.

During the course of hearing the Ld. AR submitted an application for withdrawal of appeal, relevant contents of which read as under: MOST RESPECTFULLY SHOWETH: That the above-captioned appeal is pending for adjudication before this Hon'ble Tribunal and is fixed for hearing on 03.08.2026. That due to an inadvertent clerical error, the present appeal came to be filed before this Hon'ble Tribunal with incorrect particulars pertaining to the appeal/assessment. That immediately on noticing the said mistake, the Appellant filed the correct appeal before the learned Commissioner of Income Tax (Appeals) [CIT(A)] on the very next day.

2 That the said appeal has since been duly adjudicated by the learned CIT(A), who has been pleased to allow the appeal in favour of the Appellant. Consequently, the issues involved in the present appeal no longer survive for adjudication. That in view of the above facts, the present appeal has become infructuous and the Appellant does not wish to press the same. In view of the facts and circumstances stated hereinabove, it is most respectfully prayed that this Hon'ble Tribunal may kindly permit the Appellant to withdraw the present appeal and dismiss the same as withdrawn, in the interest of justice.

4.

The Ld. DR raised no objection to the withdrawal of the appeal as sought by the Appellant.

5.

We have heard both parties and perused the material available on record. In view of the categorical submissions made in the withdrawal application filed by the Appellant, we grant permission to the Appellant to withdraw the appeal.

6.

In the result, appeal of the Appellant is dismissed as withdrawn.

Order pronounced on 04/08/2026

Sd/- Sd/- लिलत कुमार िवजय वमा� (LALIET KUMAR) (VIJAY VARMA) �ाियक सद� /JUDICIAL MEMBER लेखा सद�/ ACCOUNTANT MEMBER AG आदेश की �ितिलिप अ�ेिषत/ Copy of the order forwarded to : अपीलाथ�/ The Appellant 1. ��थ�/ The Respondent 2. आयकर आयु�/ CIT 3. आयकर आयु� (अपील)/ The CIT(A) 4. िवभागीय �ितिनिध, आयकर अपीलीय आिधकरण, च�ीगढ़/ DR, ITAT, CHANDIGARH 5. गाड� फाईल/ Guard File 6.

BY ORDER, ASSISTANT REGISTRAR INCOME TAX APPELLATE TRIBUNAL KENDRIYA SADAN, SECTOR-9A CHANDIGARH

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