What did the Tribunal hold?

The Tribunal, while deprecating the assessee's non-compliance, granted a last opportunity for the assessee to present its case. This was done in the interest of justice and fair play, subject to the assessee paying a cost of Rs. 10,000/- to the Tamil Nadu State Legal Services Authority.

The assessee, a Primary Agricultural Co-operative Credit Society, failed to respond to multiple notices from the First Appellate Authority (FAA) and the Assessing Officer (AO). Consequently, the assessment was completed on a best judgment basis, and the FAA's order was ex-parte.

What were the issues?

Whether the assessee should be granted another opportunity to present its case despite non-compliance with statutory notices, and if so, under what conditions.

R 1253L Marudhur Paccs Ltd… vs ITO | ITAT Chennai 2026

Income Tax Appellate Tribunal, ‘D’ BENCH, CHENNAI

Before: SHRI GEORGE GEORGE K & SHRI S.R. RAGHUNATHA

Hearing: 17.06.2026Pronounced: 18.06.2026

आदेश/ O R D E R PER GEORGE GEORGE K, VICE PRESIDENT: This appeal filed by the assessee is directed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 12.03.2026 passed under section 250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2019-20.

ITA No.2350/CHNY/2026 - 2 - R1253L Marudhur PACCS Ltd 2. At the very outset, we notice that the order of First Appellate Authority (FAA) is ex-parte, since there was no compliance from the assessee to three notices issued from the office of the First Appellate Authority. Further, we also note that the assessment has been completed on best judgment basis r.w.s.144 of the Act.

The Ld.AR submitted that the assessee is a Primary Agricultural Co-operative Credit Society Ltd. and the assessee society had inadvertently failed to take note of the notices issued by the FAA & AO. The Ld. AR, only pleaded that one more opportunity be granted to the assessee and the matter be restored to the file of the AO, so as to enable the assessee to effectively present his case and undertook that the assessee society would duly appear and furnish the necessary details as and when called for.

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

We have heard rival submissions and perused the materials on record. The proceedings before the AO as well as the FAA were

ITA No.2350/CHNY/2026 - 3 - R1253L Marudhur PACCS Ltd ex-parte, since the assessee did not respond to various notices issued from the office of the AO & FAA. The Ld. AR submitted that one more opportunity may be granted to the assessee to represent its case before the AO and undertook that assessee society would duly appear and furnish the necessary details as and when called for. We strongly deprecate the nonchalant attitude of the assessee in not responding to the statutory notices issued by the FAA & AO. However, considering the submissions of the Ld. AR 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 AO as a last opportunity with a condition assessee pays a cost of Rs.10,000/- (Rupees ten thousand only) to be paid to Tamil Nadu State Legal Services Authority at the Hon’ble High Court of Madras. The amount of Rs.10,000/- shall be paid within a month’s time from the date of receipt of this order and assessee shall produce the receipt for the said payment before the AO. Accordingly, the matter is remitted to the files of the AO for fresh adjudication. The AO shall afford reasonable opportunity of hearing to the assessee. The assessee is directed to co-operate with the Revenue and furnish all requisite details and evidences in support of his claim and shall not seek unnecessary adjournment. It is ordered accordingly.

ITA No.2350/CHNY/2026 - 4 - R1253L Marudhur PACCS Ltd 6. In the result, the appeal filed by the assessee is allowed for statistical purposes.

Order pronounced in the open court on 18th June,2026 at Chennai.

Sd/- Sd/- (एस.आर. रघुनाथा) (जॉज� जॉज� के) (GEORGE GEORGE K) (S.R. RAGHUNATHA) उपा�य� /VICE PRESIDENT लेखा सद�य/ACCOUNTANT MEMBER चे�नई/Chennai, �दनांक/Dated, the 18th June, 2026 RSR, Sr.PS आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��यथ�/Respondent 3. आयकर आयु�त /CIT, Madurai 4. �वभागीय ��त�न�ध/DR 5. गाड� फाईल/GF. By Order Digitally signed by REKHA REKHA SENTHIL RAJ SENTHIL RAJ Date: 2026.06.22 12:31:54 +05'30'

R 1253L MARUDHUR PACCS LTD.,LALGUDI vs. ITO, WARD-2(1), TRICHY

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