What did the Tribunal hold?

The ITAT found that the CIT(A) had not adjudicated the legal grounds raised by the assessee. Therefore, the matter was remanded to the CIT(A) for proper adjudication.

The assessee appealed to the ITAT after the CIT(A) failed to adjudicate the legal grounds raised in Form No.35. The Revenue did not dispute this lack of adjudication.

What were the issues?

Whether the CIT(A) properly adjudicated all grounds of appeal, including legal grounds, before passing an order.

Palaniappachettiar Sundaram, Salem vs ITO | ITAT Chennai 2026

Before: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

Hearing: 17.03.2026Pronounced: 12.06.2026

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appeal filed by the assessee is directed against the order dated 04.11.2025 passed by the Ld. Commissioner of Income Tax (Appeals), NFAC, Delhi for the assessment year 2019-20. 2. At the outset, it is prayed by the ld. AR, Mr. Bhupendran, Advocate, that the ld. CIT(A) did not adjudicate the legal grounds raised in Form No.35 and prayed to remand the matter to the file of the ld. CIT(A) by arguing that the assessee has a fair chance of succeeding on the legal grounds.

Ld. DR, Mr. ARV Sreenivasan, CIT, did not dispute that there was no adjudication by the ld. CIT(A) on the legal issues and reported no objection to remanding the matter to the file of the ld. CIT(A).

On perusal of Form No.35, we note that the assessee raised legal grounds in Ground Nos.2, 3 and 4 in Form No.35; however, no adjudication was done by the ld. CIT(A) in the impugned order, which is clear from para Nos.5.1 to 5.4 of the impugned order. Therefore, considering the facts and circumstances of the case, we deem it proper to remand the matter to the file of the ld. CIT(A) with a direction to adjudicate the legal grounds and pass the order in accordance with law. The assessee is at liberty to file evidence, if any, in support of his claim. The order of the ld. CIT(A) is set aside. Thus, the grounds raised by the assessee are allowed for statistical purposes

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

Order pronounced on 12th June, 2026 at Chennai. (INTURI RAMA RAO) JUDICIAL MEMBER Chennai, Dated, 12.06.2026 MM/- आदेश की "ितिलिप अ"ेिषत/Copy to: 1. अपीलाथ"/Appellant, 2.""थ"/ Respondent, 3. आयकर आयु"/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय "ितिनिध/DR & 5. गाड" फाईल/GF.

PALANIAPPACHETTIAR SUNDARAM,SALEM vs. ITO WARD I(6), SALEM

What did the Tribunal hold?

What were the facts?

What were the issues?

Which sections of the Income-tax Act were involved?

Recent GST High Court judgments