What did the Tribunal hold?

The Tribunal restored the appeal to the Assessing Officer's file. The Assessing Officer was directed to decide the issues on merits after giving the assessee an adequate opportunity to be heard.

The assessee's appeal was filed against the NFAC's order, which was based on the assessee's failure to submit crucial evidence. The assessee had also failed to respond properly before the Assessing Officer.

What were the issues?

Whether the NFAC's order, passed due to the assessee's failure to submit evidence, was justified. The need for the assessee to be provided with an opportunity to present its case.

M/S. Chengmari Tea Company Ltd. vs DCIT | ITAT Kolkata 2026

Income Tax Appellate Tribunal, “A”BENCH KOLKATA

Before: Shri Rajesh Kumar, AccountantMember & Shri Pradip Kumar Choubey, JudicialMember

आयकर अपील�य अ�धकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “A”BENCH KOLKATA Before Shri Rajesh Kumar, AccountantMember and Shri Pradip Kumar Choubey, JudicialMember ITA No.2967/Kol/2025 Assessment Year: 2022-23 M/s Chengmari Tea Company Ltd..………………….……….……….……Appellant 37, Shakespeare Sarani, Circus avenue, Kol-17. [PAN: AABCC0672Q] vs. DCIT, Circle-4(1), Kolkata…...……...…………………….....……...…..…..Respondent Appearances by: Shri Sunil Surana, FCA, appeared on behalf of the appellant. Shri Pankaj Pandey, Sr. DR,appeared on behalf of the Respondent. Date of concluding the hearing :April 23, 2026 Date of pronouncing the order :April 28 , 2026 ORDER PerPradip Kumar Choubey, Judicial Member: This appeal filed by the assessee is directed against the order dated 20.11.2025 of the NFAC, Delhi passed u/s 250 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) for the assessment year 2022– 23.

At the outset, we note that the appellate order passed by the ld. CIT(A) on the sole basis that assessee failed to submit crucial evidence. We further note that before the Assessing Officer also, the assessee failed to respond properly.

Under the circumstances, in our view, the interest of justice would be well-served if the appeal is restored to the file of the Assessing Officer with a direction to decide the issues on merits after affording adequate

ITA No.2967/Kol/2025 opportunity of being heard to the assessee. The assessee is directed to actively comply notices and submit all the relevant details before the Assessing Officer to prove its case.

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

Kolkata, the 28th April, 2026.

Sd/- Sd/- [Rajesh Kumar] [Pradip Kumar Choubey] Accountant Member Judicial Member

Dated:. 28. 04.2026. DC Copy of the order forwarded to: 1. Appellant - 2. Respondent - 3. CIT(A)- 4. CIT- , 5. CIT(DR),

//True copy// By order Assistant Registrar, Kolkata Benches

M/S. CHENGMARI TEA COMPANY LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 4(1),, KOLKATA

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