INDRAYANI BIOTECH LTD.,CHENNAI vs. ITO, CORP. WARD-2(3), CHENNAI

The Ld. AR submitted that the First Appellate Authority (FAA) dismissed the assessee's appeal ex-parte on the ground that the assessee had neither responded to the hearing notices nor furnished any supporting or cogent submissions. Consequently, the FAA confirmed the addition made by the AO u/s. 68 r.w.s 115BBE of the Act, holding that the genuineness and creditworthiness of the impugned credits remained unverified in the absence of any explanation. The Ld. AR, however, contended that the assessee had duly filed detailed written submissions in response to the notice dated 13.10.2025 through the ITBA portal, but the same were not taken into consideration by the FAA while passing the impugned order. In support of this contention, the Ld. AR produced copy of the e- Proceedings Response Acknowledgement evidencing the filing of the submissions. It was, therefore, prayed that, in the interest of justice and fair play, the matter may be restored to the file of the FAA for fresh adjudication after considering the written submissions already

The ld.DR submitted that adequate opportunities were provided from the office of the FAA and there is no violation of principles of natural justice. Therefore, it was prayed the appeal of the assessee may be dismissed.

We have heard rival submissions and perused the materials on record. The FAA dismissed the appeal of assessee by observing that no reply/evidence was filed by the assessee to explain the credits in assessee’s bank statements. However, the Ld. AR submitted that the assessee had, in fact, filed written submissions in response to the notice through the ITBA portal and that the same were not considered by the FAA while passing the impugned order. A copy of the e-Proceedings Response Acknowledgement has also been placed on record in support of this contention. Considering the above facts and in the interest of justice and fair play, we are of the view that the matter ought to be restored to the files of the FAA for fresh adjudication. The assessee is directed to extend full cooperation during the appellate proceedings and furnish all necessary documents and evidences to establish the identity, creditworthiness and

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