WALL ROCK INFRATECH PVT LTD,DELHI vs. JCIT, CENTRAL RANGE-4, NEW DELHI

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ITA 2188/DEL/2026Status: DisposedITAT Delhi16 July 2026AY 2019-203 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal set aside the orders of the CIT(A) and remanded the matters back for fresh consideration. The assessee is to be granted an opportunity of being heard and to present evidence.

What were the facts?

The assessee filed appeals against penalty orders under Section 271D, confirmed by the CIT(A). No one appeared on behalf of the assessee during the hearing.

What were the issues?

Whether the penalty under Section 271D was rightly confirmed without affording the assessee an opportunity of being heard. The need for a fresh hearing to consider evidence.

Which sections of the Income-tax Act were involved?

Section 271D,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “B”: NEW DELHI

Before: MS MADHUMITA ROY & SMT. RENU JAUHRI

For Respondent: Shri Rajesh Kr. Dhanesta, Sr. DR
Hearing: 16/07/2026Pronounced: 16/07/2026

Heard together (2 matters)

ITA No. 2189/Del/2026
ITA No. 2191/Del/2026

Read from the judgment's own cause title. This page is filed under one of them.

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”: NEW DELHI BEFORE MS MADHUMITA ROY, JUDICIAL MEMBER AND SMT. RENU JAUHRI, ACCOUNTANT MEMBER

ITA No. 2188/Del/2026 (A.Y 2019-20) ITA No. 2189/Del/2026 (A.Y 2020-21) ITA No. 2190/Del/2026 (A.Y 2021-22) ITA No. 2191/Del/2026 (A.Y 2022-23)

M/s Wall Rock Infratech Pvt. Vs. JCIT Ltd. C/o Advocate Deepak Central Range-4 Kapoor, 59, Nehru Apartments, Delhi Outer Ring Road, Kalkaji, New Delhi (Appellant) (Respondent) PAN: AABCWQ3055H

Assessee by : None Revenue by: Shri Rajesh Kr. Dhanesta, Sr. DR Date of Hearing 16/07/2026 Date of pronouncement 16/07/2026

O R D E R PER BENCH The bunch of appeals filed by the Assessee are directed against all

orders dated 30.12.2025 passed by the Ld. Commissioner of Income-tax

(Appeals)-26, Delhi [hereinafter referred to as the Ld. CIT(A)] under Section

250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for

Assessment Years 2019-20 to 2022-23 respectively.

2.

Since all the appeals relate to the same assessee these are heard

analogously and are being disposed of by a common order for the sake of

convenience.

2 ITA Nos 2188 to 2191/Del/2026 Wall Rock Infratecdh Pvt. Ltd.

3.

The matter relates to penalty under Section 271D of the Act confirmed

by the First Appellate Authority dated 30.12.2025 arising out of the order

dated 27.09.2024 passed by the Central Range-4, Delhi.

4.

None appeared on behalf of the Assessee inspite of notice having been

served. Since, admittedly, an ex-parte order passed by the Ld. CIT(A) in

each matters in order to prevent the miscarriage of justice we would like to

give a further opportunity to the Assessee to represent the case before the

authorities below effectively and thus, all these appeals are disposed of by

setting aside the issue to the file of the Ld. CIT(A) for consideration of the

same afresh upon granting an opportunity of being heard to the Assessee

and upon considering the evidence on record or any other evidence which

the Assessee may choose to file at the time of hearing of the matter.

5.

We further make it clear that in the event the Assessee does not co-

operate with the First Appellate Authority, the said authority would be at

liberty to proceed and finalize the issues strictly in accordance with law.

6.

All the appeals filed by the Assessee are therefore, allowed for

statistical purpose.

Order pronounced in the open court on 16/07/2026.

(RENU JAUHRI) (MADHUMITA ROY) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 16/07/2026 R. Naheed, Sr PS

3 ITA Nos 2188 to 2191/Del/2026 Wall Rock Infratecdh Pvt. Ltd.

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