R. RAJA,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(2), CHENNAI

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ITA 2467/CHNY/2026Status: DisposedITAT Chennai17 June 2026AY 2022-234 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal, while deprecating the assessee's non-compliance, granted one last opportunity to present the case before the AO. This was subject to a cost of Rs. 25,000/- to be paid to the Tamil Nadu State Legal Services Authority.

What were the facts?

The assessee failed to comply with notices issued by the CIT(A) and AO, leading to ex-parte orders. The assessments were completed on a best judgment basis. The assessee's representative requested one more opportunity to present the case.

What were the issues?

Whether the assessee should be granted another opportunity to present their case before the AO despite previous non-compliance, and the validity of ex-parte assessment orders.

Which sections of the Income-tax Act were involved?

Section 147,Section 145,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D’ BENCH, CHENNAI

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

Hearing: 17.06.2026Pronounced: 17.06.2026

आदेश/ O R D E R PER GEORGE GEORGE K, VICE PRESIDENT: These appeals filed by the assessee are directed against four orders of the Commissioner of Income Tax (Appeals), Chennai-18 all dated 17.02.2026 passed under section 250 of the Income Tax

ITA Nos.2464 to 2467/CHNY/2026 - 2 - R Raja Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Years are 2019-20, 2020-21, 2021-22 & 2022-23 respectively.

2.

At the very outset, we notice that the orders of CIT(A) are ex-parte, since there was no compliance from the assessee to various notices issued from the office of the CIT(A). Further, we also note that the assessments have been completed on best judgment basis r.w.s.147 r.w.s. 145of the Act.

3.

The ld.AR submitted that the assessee had failed to take note of the notices issued by the CIT(A) & AO and hence, remained ex-parte. The Ld.AR undertook that he would duly appear and furnish the necessary details as and when called for. 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.

4.

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

ITA Nos.2464 to 2467/CHNY/2026 - 3 - R Raja 5. We have heard rival submissions and perused the materials on record. The proceedings before the AO as well as the FAA were ex-parte, since the assessee did not respond to various notices issued from the office of the AO & CIT(A). The Ld. AR submitted that one more opportunity may be granted to the assessee to represent his cases before the AO and undertook that he 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 CIT(A) & 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 matters ought to be restored to the files of the AO as a last opportunity with a condition assessee pays a cost of Rs.25,000/- (Rupees twenty five thousand only) to be paid to Tamil Nadu State Legal Services Authority at the Hon’ble High Court of Madras. The amount of Rs.25,000/- 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

ITA Nos.2464 to 2467/CHNY/2026 - 4 - R Raja support of his claim and shall not seek unnecessary adjournment. It is ordered accordingly.

6.

In the result, the appeals filed by the assessee are allowed for statistical purposes.

Order pronounced in the open court on 17th 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 17th 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, Chennai 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 12:27:44 +05'30'

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