RAMANATHANPURAM DIST CENTRAL CO OPERATIVE BANK LIMITED,RAMANNATHAPURAM vs. ITO, RAMANATHPURAM
In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.
What did the Tribunal hold?
The Tribunal held that the appeals were not maintainable as the issues were already pending before the CIT(A) in relation to the assessment under Section 143(3). For the second appeal, the CIT(A)'s dismissal for non-submission of evidence was upheld.
What were the facts?
The assessee, a co-operative bank, filed appeals against assessment orders for AY 2013-14 and 2014-15. The issues raised in the appeals were also pending before the CIT(A) in relation to assessment orders under Section 143(3).
What were the issues?
Maintainability of appeals when identical issues are pending before the first appellate authority and justification for dismissal of grounds due to non-submission of evidence.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Before: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi
आयकर अपीलीय अिधकरण, ’ ए’ �ायपीठ, चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI �ी इंटूरी रामाराव, लेखा सद� एवं �ी एस.एस. िव�ने� रिव, �ाियक सद� के सम� । Before Shri Inturi Rama Rao, Accountant Member & Shri S.S. Viswanethra Ravi, Judicial Member आयकर अपील सं./I.T.A. Nos.3412 & 3413/Chny/2025 िनधा�रण वष�/Assessment Year: 2013-14 & 2014-15
Ramanathanpuram District Vs. The Income Tax Officer, Central Co. Operative Bank LTD., Ramanathapuram, Post box No.25, 265-E, Vandikkara, 623501. Street, Ramanathapuram, Tamil Nadu, 623 501. [PAN: AAIFR2500A] (अपीलाथ�/Appellant) (��थ�/Respondent) अपीलाथ� की ओर से / Appellant by : Mr. R. Prasanna Venkatesan, F.C.A. ��थ� की ओर से/Respondent by : Ms. R. Anita, CIT सुनवाई की तारीख/ Date of hearing : 10.06.2026 घोषणा की तारीख /Date of Pronouncement 03.08.2026 : आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:
Both the appeals filed by the assessee are directed against separate orders, both dated 25.09.2025, passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for the assessment years 2013-14 & 2014-15 respectively.
Since the issues raised in both these appeals are similar and based on the same identical facts, with the consent of both the parties, we
I.T.A. Nos. 3412 & 3413/Chny/2025 2
proceed to hear both the appeals together and pass a consolidated order for the sake of convenience.
-:I.T.A. No.3412/Chny/2025:- (Assessment Year: 2013-14) 3. At the outset, we find that the assessee raised four grounds of appeal in the present appeal, which are part and parcel of the assessment made under Section 143(3) of the Income-tax Act, 1961 (for short, the Act). We note that the ld. AR, Mr. R. Prasanna Venkatesan, F.C.A., submitted that the assessee also challenged the said assessment order in the first appellate proceedings and that it is pending adjudication before the ld. CIT(A).
Ld. DR, Ms. R. Anita, CIT, argued that the same issues raised are pending before the ld. CIT(A) in terms of the challenge to the assessment made under Section 143(3) of the Act. Therefore, the appeal before us is not maintainable and prayed to dismiss the same.
On perusal of the assessment order dated 21.09.2021 passed under Section 147 read with Section 144B of the Act, which clearly shows that the AO made the computation taking into account the total income determined for the same AY under Section 143(3) of the Act at ₹4,93,06,280, which is evident from pages No. 13 and 14 of the assessment order. Therefore, we find force in the arguments of the ld. DR that since the issues forming part of the order under Section 143(3) of the Act, the issues raised before us in the reassessment proceedings are not maintainable. Accordingly, the grounds raised by the assessee are dismissed.
I.T.A. Nos. 3412 & 3413/Chny/2025 3
In the result, the appeal of the assessee is dismissed.
-:I.T.A. No.3413/Chny/2025:- (Assessment Year: 2014-15) 7. At the outset, it is noted that the assessee challenged the assessment order dated 21.09.2021 passed under Section 147 read with Section 144B of the Act before the ld. CIT(A). On perusal of the impugned order, the ld. CIT(A) primarily dismissed all the grounds for non- submission of evidence, which is evident from para Nos. 6.4, 6.5, 6.6, 6.7, 6.8, 6.9, 6.10 and 6.11. Therefore, the arguments of the ld. AR, Mr. R. Prasanna Venkatesan, F.C.A., are not acceptable to remand the matter to the file of the ld. CIT(A) for any opportunity. Admittedly, the assessee is a co-operative bank having established its business for several years, and non-submission of the required details before the authorities is not justified. Therefore, we find no infirmity in the order of the ld. CIT(A), and the same is justified. Thus, the grounds raised by the assessee are dismissed.
In the result, the appeal of the assessee is dismissed
Order pronounced on 3rd August, 2026 at Chennai.
Sd/- Sd/- (INTURI RAMA RAO) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER Chennai, Dated, 03.08.2026
I.T.A. Nos. 3412 & 3413/Chny/2025 4
MM/- आदेश की �ितिलिप अ�ेिषत/Copy to: 1. अपीलाथ�/Appellant, 2.��थ�/ Respondent, 3. आयकर आयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR & 5. गाड� फाईल/GF.
MANIS Digitally signed by MANISH H MISHRA Date: MISHRA 2026.08.06 10:56:31 +05'30'
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