PRAKRUTHI CHITS PRIVATE LIMITED,,BANGALORE vs. INCOME TAX OFFICER, WARD-5(1)(3), BANGALORE

ITA 2510/BANG/2025Status: DisposedITAT Bangalore28 September 2026AY 2017-183 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the appeal filed by the assessee was not maintainable. The primary reason for this decision was the non-compliance with procedural requirements. The Registry had noted several defects, including the appeal fees being paid under an incorrect head, and Form 36 along with the grounds of appeal not being signed by the appellant. The assessee had not rectified these defects. In accordance with Rule 4A(2)(iv) of the ITAT Rules, 1963, an appeal cannot be proceeded with if such defects are not removed. Therefore, the Tribunal found it necessary to return the appeal and application back to the assessee company. The substantive grounds of appeal concerning additions under Section 68 and the CIT(A)'s findings were not examined due to the preliminary procedural defects.

What were the facts?

The assessee, Prakruthi Chits Private Limited, Bengaluru, filed an appeal against the order of the CIT(A)/NFAC, Delhi, dated 03.09.2025, for the assessment year 2017-18. The appeal was challenged based on several grounds, including the CIT(A)'s observations regarding demonetization period customer payments and the acceptance of cash transaction details. The ITAT Bench noted that the assessee's appeal was not in order due to defects such as incorrect appeal fee payment, and Form 36 and grounds of appeal not being signed by the appellant. These defects were not rectified by the assessee. The respondent was represented by the Addl. CIT-DR, while none appeared for the appellant.

What were the issues?

1. Whether the appeal filed by the assessee is maintainable in light of defects in the filing, specifically regarding the payment of appeal fees and the signing of Form 36 and grounds of appeal, as per Rule 4A(2)(iv) of the ITAT Rules, 1963. Assessee's Contentions (implied through grounds of appeal): The assessee contended that the CIT(A)'s order was opposed to law and facts. They argued that they submitted documents and details to the CIT(A), including identity and details of customers who paid old dues during demonetization. They also claimed that cash transaction details submitted to the Income Tax Department were accepted, making an addition under Section 68 incorrect. Furthermore, the assessee alleged that the CIT(A) failed to examine their submissions and judicial pronouncements, and did not call for specific documents, despite the assessee having furnished all details to the Assessing Officer. Revenue's Contentions: The judgment does not record specific contentions from the revenue regarding the substantive issues of the appeal. The revenue was represented by the Addl. CIT-DR.

Which sections of the Income-tax Act were involved?

Section 68,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B’’BENCH: BANGALORE

Before: SHRI BALAKRISHNAN S. & SHRI KESHAV DUBEY

Hearing: 08.07.2026Pronounced: 28.09.2026

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of the ld. CIT(A)/NFAC, Delhi dated 03.09.2025 vide DIN & Order No. ITBA/NFAC/S/250/2025-26/1080325720(1) passed u/s 250 of the Income Tax Act, 1961 (in short “the Act”) for the assessment year 2017-18. 2. The assessee has raised the following grounds of appeal:-

1.

CIT (A) order is opposed to the Law and facts.

2.

CIT (A) in Para 2 has observed that in reply to notice u/s 250 with reply appellant submitted, documents and details to CIT (A).

3.

In Para 4.4 CIT (A) has observed that demonetization period customers paid old

The order continues below.

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