What did the Tribunal hold?

The Tribunal found that the CIT(A) had inadvertently failed to adjudicate all grounds of appeal, which is mandatory. Therefore, the Tribunal set aside the CIT(A)'s order and remanded the case back for fresh adjudication of all grounds.

The assessee filed an appeal against the CIT(A)'s order. The assessee contended that the CIT(A) failed to adjudicate two specific grounds of appeal (Grounds 6 and 7). The CIT(A) had reproduced these grounds but did not provide any decision on them.

What were the issues?

Whether the CIT(A) properly adjudicated all grounds of appeal raised by the assessee. The primary issue was the failure of the CIT(A) to decide specific grounds of appeal.

Adhiraj Cements vs DCIT | s.250 | ITAT Raipur 2026

Income Tax Appellate Tribunal, RAIPUR BENCH “DB”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL Dr. DIPAK P. RIPOTE

For Appellant: Shri Hardik Jain, CA

For Respondent: Shri Rituparna Namdeo, CIT- DR

Hearing: 27.07.2026Pronounced: 31.07.2026

आदेश / ORDER PER BENCH :

This appeal is filed by the assessee against the order of the Commissioner of Income Tax (Appeals) [CIT(A)], National Faceless Appeal Centre (NFAC), Delhi, passed under section 250 of the Income Tax Act, 1961 (‘the Act’) for the Assessment Year (AY) 2020-21 on 25.11.2025 emanating from assessment order under section 143(3) rws 144B of the Act dated 22.09.2022.

ITA No. 76/RPR/2026 Adhiraj Cements

Findings and Analysis :

We have heard both parties and perused the records. In this case, Ld. AR submitted that Ld. CTI(A) has failed to adjudicate ground Nos. 6 and 7 raised by the assessee which have been reproduced by the Ld. CIT(A) but not adjudicated.

Ld. DR merely relied on the order of the Ld. AO and Ld. CIT(A).

We have perused the order of Ld. CIT(A) and noted that inadvertently Ld. CIT(A) has failed to adjudicate the grounds No. 6 and 7 raised by the assessee. As per section 250 of the Act, it is mandatory for Ld. CIT(A) to adjudicate all the grounds raised by the assessee. In these facts and circumstances of the case and in the interest of justice, we set aside the order of Ld. CIT(A) to Ld. CIT(A) for denovo adjudication. The assessee shall file all the details before the Ld. CIT(A). Ld. CIT(A) shall provide proper opportunity of hearing to the assessee and also consider all the grounds raised by the assessee. Accordingly, the appeal of the assessee is allowed for statistical purposes.

ITA No. 76/RPR/2026 Adhiraj Cements

In the result, appeal of the assessee is allowed for statistical purposes.

Order pronounced on this 31st day of July, 2026.

Sd/- Sd/- (PARTHA SARATHI CHAUDHURY) (Dr. DIPAK P. RIPOTE) JUDICIAL MEMBER ACCOUNTANT MEMBER रायपुर / Raipur; िदनांक / Dated : 31st July, 2026. HKS, PS

आदेश की �ितिलिप अ�ेिषत / Copy of the Order forwarded to : अपीलाथ� / The Appellant. 1. ��थ� / The Respondent. 2. 3. The Pr. CIT concerned. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, “SMC” ब�च, 4. रायपुर / DR, ITAT, “SMC” Bench, Raipur. गाड� फ़ाइल / Guard File. 5.

आदेशानुसार / BY ORDER, Digitally signed Hem Kumari //True copy// by Hem Kumari Shrivastava, Shrivastava, PS, //True copy// PS, ITAT, ITAT, Raipur Date: 2026.07.31 Raipur 17:21:02 +05'30' // True Copy // Private Secretary, आयकर अपीलीय अिधकरण, रायपुर / ITAT, Raipur.

ADHIRAJ CEMENTS, RAIPUR,RAIPUR vs. DCIT, CIRCLE-1(1), RAIPUR, RAIPUR

What did the Tribunal hold?

What were the facts?

What were the issues?

Which sections of the Income-tax Act were involved?

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