PRA PANELS PRIVATE LIMITED,RAIPUR vs. INCOME TAX OFFICER WARD 1(2), RAIPUR

ITA 337/RPR/2026Status: DisposedITAT Raipur13 July 2026AY 2023-244 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the assessee should not be prejudiced by the internal functioning of the department regarding the allotment of appeals. The matter of entitlement to the 15% tax rate under Section 115BAB needs to be adjudicated on merits by the First Appellate Authority.

What were the facts?

The assessee claimed a lower tax rate of 15% under Section 115BAB by filing Form 10-ID, but this claim was denied by the CPC. A rectification application under Section 154 was also disposed of without changes. The appeal to the JCIT(A) was dismissed on the grounds that Section 154 orders are not appealable under Section 246.

What were the issues?

Whether an order under Section 154 of the Income Tax Act is appealable to the CIT(Appeals) and whether the assessee is entitled to the concessional tax rate under Section 115BAB.

Which sections of the Income-tax Act were involved?

Section 154,Section 143(1),Section 115BAB,Section 246,Section 246A

AI-generated summary — verify with the full judgment below

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

Before: SHRI PARTHA SARATHI CHAUDHURY & SHRI AVDHESH KUMAR MISHRA

For Appellant: Shri Abhishek Mahawar, CA
For Respondent: Shri Piyush Tripathi, Sr. DR
Hearing: 10.07.2026Pronounced: 13.07.2026

PER PARTHA SARATHI CHAUDHURY, JM: The present appeal preferred by the assessee emanates from the order of the Ld.ADDL/JCIT(A)-2, Vadodara dated 27.03.2026 for the assessment year 2023-24 as per the grounds of appeal on record.

2.

The brief facts in this case are that the assessee had filed rectification application u/s.154 of the Income Tax Act, 1961 (for short ‘the Act’) dated 30.01.2025 challenging the validity of the intimation u/s

The order continues below.

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