RANGASAMY JAGANATHAN,COIMBATORE vs. DCIT,CENTRAL CIRCLE-1,COIMBATORE, COIMBATORE

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ITA 304/CHNY/2026Status: DisposedITAT Chennai04 August 2026AY 2018-194 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the order of the CIT(A) as the assessee failed to prosecute the appeal by not appearing or providing any supporting material. The grounds raised by the assessee were found to be unsupported.

What were the facts?

The assessee filed a return of income, which was later selected for scrutiny. The Assessing Officer made significant disallowances and additions. The CIT(A) confirmed the assessment order after the assessee failed to appear or submit any documents.

What were the issues?

Whether the additions made by the AO and confirmed by the CIT(A) are valid when the assessee fails to appear or provide evidence. The assessee's failure to prosecute the appeal.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144B,Section 40(a)(ia),Section 263

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH, CHENNAI

Before: SHRI S.S. VISWANETHRA RAVI & SHRI S. R. RAGHUNATHA

Hearing: 30.06.2026Pronounced: 04.08.2026

आयकर अपीलीय अधिकरण, ‘सी’ न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI श्री एस एस विश्वनेत्र रवि, न्याविक सदस्य एवं श्री एस. आर. रघुनाथा, लेखा सदस्य के समक्ष BEFORE SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBER AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.304/Chny/2026 ननिाारण वर्ा / Assessment Year: 2018-19 Rangasamy Jaganathan The Deputy Commissioner of 1473 Nadar Colony, Trichy Road vs. Income-tax Coimbatore South Central Circle 1 Coimbatore – 641 018. Coimbatore. [PAN: AFNPJ0370C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant by : --- None --- प्रत्यर्थी की ओर से/Respondent by : Ms.Nayani Swapna, CIT

सुनवाई की तारीख/Date of Hearing : 30.06.2026 घोर्णा की तारीख/Date of Pronouncement: 04.08.2026 आदेश /O R D E R PER S.R. RAGHUNATHA, AM : This appeal has been preferred by the Assessee against the order passed by the Learned Commissioner of Income Tax, Appeal, CIT(Appeals), National Faceless Appeal Centre, Delhi, [hereinafter referred to as “the Ld. CIT(A)”], dated 11.12.2025, arising from the assessment order dated 23.09.2021 for the Assessment Year (AY) 2018-19 passed by the Assessing Officer, National Faceless Assessment Centre, Delhi [hereinafter referred to as

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“the AO”], u/s. 143(3) r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as “the Act”).

2.

The brief facts of the case emanating from the records are that the assessee is an individual, filed his return of income for the AY 2018-19 on 29.09.2018 declaring total income of Rs.13,05,500/-. The return was processed by the CPC and issued intimation u/s.143(1) of the Act dated 10.12.2019. Later, the case was selected for complete scrutiny under CASS for verification of genuineness of the expenses. The assessment was completed u/s.143(3) r.w.s. 144B of the Act dated 23.09.2021 by making a disallowance of commission payment to the tune of Rs.4,87,90,500/- and also making an addition u/s.40(a)(ia) of the Act of Rs.2,59,362. Subsequently, the ld.PCIT on examination of records found errors in the order, which is prejudicial to the interest of the Revenue, and hence, passed a revisionary order u/s.263 of the Act dated 17.08.2023. Pursuant to the order of the ld.PCIT, the AO completed the assessment u/s.143(3) r.w.s. 263 of the Act by making an addition of Rs.5,50,52,789/- for non-proving of genuineness of the turnover. 3. Aggrieved by the order of the AO, the assessee preferred an appeal before the ld.CIT(A). The assessee did not file any online submission before the ld.CIT(A) as stated in para 4 of the order of the ld.CIT(A). Further, the assessee did not respond to any of the notices for hearing issued by the ld.CIT(A) from 30.06.2025 to 26.11.2025 (six opportunities) as stated in para 6.1 of the order. Hence, the ld.CIT(A) left with no other option confirmed the order of the AO by dismissing the appeal of the assessee based on the available records and passed an order dated 11.12.2025. 4. Aggrieved by the order of the ld.CIT(A), the assessee is in appeal before us. The Registry fixed the date of hearing on 05.05.2026, wherein the ld.AR for the assessee Mr. R.Anish Kumar, Advocate appeared and sought for an adjournment to 23.06.2026. Again, the ld.AR sent an adjournment letter seeking

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for adjournment and the case was posted for hearing on 30.06.2026. On that day, when the case was called out for hearing, none appeared for the assessee. 5. Per contra, the ld.DR supported the orders of the authorities and stated that the assessee is negligent in participation for the proceedings both before the ld.CIT(A) as well as the Tribunal, hence, prayed for dismissal of the appeal. 6. We have heard the submissions of the ld.DR and carefully perused the orders of the lower authorities as well as the material available on record. It is an admitted fact that the assessment pursuant to the revisionary order passed u/s.263 of the Act was completed after the assessee failed to furnish the requisite details called for by the AO. Aggrieved by the said assessment order, the assessee preferred an appeal before the ld. CIT(A). However, despite being afforded as many as six opportunities of hearing between 30.06.2025 and 26.11.2025, as recorded in paragraph 6.1 of the impugned appellate order, the assessee neither filed any written submissions nor produced any material in support of the grounds raised before the ld.CIT(A). Consequently, the ld.CIT(A), having no assistance from the assessee, adjudicated the appeal on the basis of the material available on record and confirmed the assessment order. 7. Before us also, the conduct of the assessee has remained the same. Initially, on 05.05.2026, the ld.AR sought an adjournment, which was granted. Thereafter, another adjournment request was made, and the appeal was posted for hearing on 30.06.2026. On the said date, when the matter was called for hearing, none appeared on behalf of the assessee, nor was any application filed explaining the absence or seeking any further adjournment. Thus, despite sufficient opportunities having been granted both before the ld.CIT(A) as well as before this Tribunal, the assessee has chosen not to prosecute the appeal. 8. In the present case, we find that the assessee has not brought any material before us to controvert the factual findings recorded by the Assessing Officer or the ld.CIT(A). The grounds raised in the memorandum of appeal remain unsupported by any evidence or submissions. We have independently

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examined the assessment order, the impugned appellate order and the material available on record and find no infirmity in the order of the ld.CIT(A) warranting our interference. The findings recorded by the lower authorities remain uncontroverted and there is nothing on record to demonstrate that the additions made by the AO or their confirmation by the ld. CIT(A) suffer from any factual or legal infirmity. 9. In view of the foregoing discussion, and on appreciation of the material available on record, we uphold the order of the ld.CIT(A). Accordingly, the grounds raised by the assessee fail and are dismissed. 10. In the result, the appeal field by the assessee is dismissed.

Order pronounced in the court on 04th August, 2026 at Chennai.

Sd/- Sd/- (एस एस विश्िनेत्र रवि) (एस. आर. रघुनार्था) (S.S. VISWANETHRA RAVI) (S. R. RAGHUNATHA) न्याययक सदस्य/Judicial Member लेखा सदस्य/Accountant Member

चेन्नई/Chennai, ददनांक/Dated, the 04th August, 2026. Devadas आदेश की प्रनतललपप अग्रेपर्त/Copy to: 1. अपीलार्थी/Appellant 2. प्रत्यर्थी/Respondent 3.आयकर आयुक्त/CIT– Chennai/Coimbatore/Madurai/Salem 4. पवभागीय प्रनतननधि/DR DEVADAS 5. गार्ा फाईल/GF Digitally signed by DEVADAS GOPALANACHARY GOPALANACHARY Date: 2026.08.06 09:18:23 +05'30'

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