ROLLWELL FORGE PRIVATE LIMITED,SHAPAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1), RAJKOT

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ITA 423/RJT/2026Status: DisposedITAT Rajkot02 July 2026AY 2020-213 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found it appropriate to adjudicate the current appeal along with the pending quantum appeal. Therefore, the order of the CIT(A) was set aside and the issue was remitted back to the CIT(A).

What were the facts?

The assessee filed an appeal against the reassessment order for AY 2020-21, which included disallowance of interest expenses. A related quantum appeal for AY 2016-17 was pending before the CIT(A).

What were the issues?

Whether the reassessment and reopening of assessment were bad in law, and whether the disallowance of interest expenses was justified. The primary issue was the clubbing of appeals for common adjudication.

Which sections of the Income-tax Act were involved?

Section 147,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: DR. ARJUN LAL SAINI

Hearing: 08/04/2026Pronounced: 02/07/2026

आयकरअपीलीयअिधकरण,राजकोट�ायपीठ,राजकोट। IN THE INCOME TAX APPELLATE TRIBUNAL, “SMC” RAJKOT BENCH, RAJKOT

BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER आयकरअपीलसं/.ITA No. 423/RJT/2026 �नधा�रणवष�/ Assessment Year: 2020-21 Rollwell Forge Pvt. Ltd. Deputy Commissioner of Income Sr. No. 239/1, Plot No. 1, 8 – B N H, Vs. Tax, Circle – 1(1) Shapar, Veraval, Rajkot (Gujrat) Aayakar Bhavan, Race Course Ring 360002 Road, Rajkot – 360001 �थायीलेखासं./जीआइआरसं./PAN/GIR No.: AABCR0080P (अपीलाथ�/Appellant) (��यथ�/Respondent)

�नधा�रतीक�ओरसे/Assessee by : Shri Vipul Dattani, Ld.AR राज�वक�ओरसे/Revenue by : Shri Abhimanyu Singh Yadav, Ld. Sr. DR सुनवाईक�तार�ख /Date of Hearing : 08/04/2026 घोषणाक�तार�ख /Date of Pronouncement : 02/07/2026

ORDER Per, Dr. Arjun Lal Saini, AM:

Captioned appeal filed by the assessee, pertaining to Assessment Year 2020-21, is directed against the order passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax (Appeals), dated 09.01.2026, which in turn arises out of an order passed by the Assessing Officer u/s 147 of the Act, on 27.03.2024. 2. Grounds of appeal raised by the assessee are as follows:

“1. The reassessment order u/s. 147 of the Act is bad in law.

ITA No. 423/RJT/2026 Rollwell Forge Pvt. Ltd.

2.

The reopening of assessment u/s. 147 of the Act is bad in law. 3. The learned Assessing officer has erred in law as well as on facts in making the disallowance of interest expenses of Rs. 1,41,725/- on account of unexplained expenses.”

3.

At the outset, the Ld. Counsel for the assessee submitted that the appeal pertaining to quantum proceedings for AY – 2016-17 is pending before the Ld.CIT(A) for adjudication. The present appeal before the Tribunal in ITA No. 423/Rjt/2026 for AY 2020-21 pertaining to interest expenses on the principal amount, therefore the Ld.Counsel for the assessee prayed the Bench that this matter may be remitted back to the file of the Ld.CIT(A) with the direction to the Ld.CIT(A) to club this appeal with the quantum appeal for AY 2016-17 and adjudicate both the appeals together.

4.

The ld. DR for the Revenue did not have any objection if the matter is restored back to the file of the Ld.CIT(A).

5.

I have heard both the parties and carefully gone through the submission put forth on behalf of the assessee along with the documents furnished and the case laws relied upon, and perused the fact of the case including the findings of the ld CIT(A) and other materials brought on record. I note that the appeal pertaining to quantum proceedings for AY 2016-17 is pending before the Ld.CIT(A) and this appeal before us, is pertaining to interest on the principal amount for AY 2020- 21, therefore, I find that since the quantum appeal is pending before the Ld.CIT(A) for AY 2016-17, therefore, the interest imposed on quantum amount which was added by the assessing officer in AY 2016-17, and the interest amount which is added on the quantum amount for AY 2020-21, the present appeal, should be heard together, and should be adjudicated together, therefore I set aside the order of the Ld.CIT(A) and remit the issue back to the file of the Ld.CIT(A)

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ITA No. 423/RJT/2026 Rollwell Forge Pvt. Ltd.

with the direction to the Ld.CIT(A) to adjudicate these appeal pertaining to interest expenses alongwith quantum appeal for AY 2016-17. The assessee is also directed to submit relevant documents and evidences before the Ld.CIT(A) as and when call for and do not ask for unnecessary adjournment. For statistical purposes, the appeal of the assessee is treated as allowed.

6.

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

Order is pronounced in the open court on 02/07/2026. Sd/- (Dr. Arjun Lal Saini) लेखा सद�/Accountant Member राजकोट/Rajkot (True Copy) िदनांक/ Date : 02/07/2026 Copy of the order forwarded to :  The assessee  The Respondent  CIT  The CIT(A)  DR, ITAT, RAJKOT  Guard File By order Assistant Registrar/Sr. PS/PS ITAT, Rajkot

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