SHRI MANDORANA VIVIDH KARYAKARI SAHKARI MANDLI LIMITED ,MANODRANA vs. INCOME TAX OFFICER WARD-4, JND-VERAVAL

ITA 912/RJT/2026Status: DisposedITAT Rajkot30 September 2026AY 2019-203 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the CIT(A) passed the impugned order without considering the assessee's written submissions, which amounts to a violation of the principles of natural justice and fair play. The Tribunal noted that it is settled law that an affected party must be granted a sufficient opportunity to be heard. Therefore, without delving into the merits of the case, the Tribunal, in the interest of justice, set aside the order of the CIT(A) and remitted the matter back to the file of the Ld. CIT(A) for de novo adjudication. The CIT(A) was directed to pass a speaking order after affording sufficient opportunity of being heard to the assessee. The assessee was also directed to contest their stand forthwith. The appeals were allowed for statistical purposes.

What were the facts?

The assessee, Shri Mandorana Vividh Karyakari Sahkari Mandali Limited, filed four appeals against orders passed by the National Faceless Appeal Centre (NFAC), Delhi, for Assessment Years 2018-19 and 2019-20. These appeals arose from orders passed by the Assessing Officer under Section 147 read with Section 144 of the Income Tax Act, 1961. The assessee contended before the Tribunal that their detailed written submissions and comparable cases were not considered by the CIT(A), and they sought an opportunity to present additional evidence and plead their case before the First Appellate Authority. The Revenue did not object to the matter being restored to the CIT(A).

What were the issues?

1. Whether the CIT(A) erred in passing an order without considering the assessee's detailed written submissions and comparable cases, thereby violating the principles of natural justice? (Question of law and fact, concerning the procedural fairness of the appeal process). Assessee's Contention: The assessee argued that the CIT(A) failed to consider their detailed written submissions and comparable cases. They also wished to submit additional evidence and therefore requested an opportunity to plead their case before the First Appellate Authority. Revenue's Contention: The Revenue did not object to the matter being restored back to the file of the Ld. CIT(A).

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

Hearing: 30/09/2026Pronounced: 30/09/2026

Per, Dr. Arjun Lal Saini, AM:

Captioned four appeals filed by assessee, pertaining to Assessment Year 2018-19 and 2019-20, are directed against the separate orders 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 19.05.2026, which in turn arise out of separate orders passed by the Assessing Officer u/

The order continues below.

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