KIA CORPORATION,ANDHRA PRADESH vs. ACIT,INTERNATIONAL TAXATION-1(2), BANGALORE

ITITA 813/BANG/2025Status: DisposedITAT Bangalore11 September 2025AY 2022-232 pages

In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the appeal filed by the assessee (IT(IT)A No. 813/Bang/2025) was infructuous. This decision was based on the fact that another appeal (IT(IT)A No. 644/Bang/2025) for the same Assessment Year 2022-23 and against the identical assessment order had already been disposed of by the Tribunal on 30/06/2025. The Tribunal confirmed with the Registry that both appeals were registered. Since a parallel appeal covering the same subject matter had already been decided, the Tribunal found no necessity to adjudicate the present appeal. The ratio decidendi is that when a matter has already been decided between the same parties for the same assessment year and against the same order, a subsequent identical appeal becomes infructuous. The operative direction was to dismiss the appeal.

What were the facts?

The assessee, M/s. KIA Corporation, filed an appeal (IT(IT)A No. 813/Bang/2025) before the Income Tax Appellate Tribunal (ITAT), Bangalore, challenging an order passed by the Assistant Commissioner of Income Tax, International Taxation, Circle 1(2), Bangalore, for Assessment Year 2022-23. The ITAT was informed that another appeal concerning the same Assessment Year and the same assessment order, filed electronically and numbered IT(IT)A No. 644/Bang/2025, had already been disposed of on 30/06/2025. The present appeal was filed in physical form. The ITAT verified with the Registry that both appeals were registered. Due to the prior disposal of the electronically filed appeal, the Tribunal decided not to adjudicate the present appeal.

What were the issues?

1. Whether the appeal filed by the assessee is infructuous, given that a similar appeal for the same assessment year and against the same assessment order has already been disposed of by the Tribunal. Assessee's contention: The assessee did not present any arguments as the appeal was dismissed on procedural grounds. The judgment does not record any specific contentions from the assessee regarding the substantive issues of the assessment. Revenue's contention: The revenue did not present any arguments as the appeal was dismissed on procedural grounds. The judgment does not record any specific contentions from the revenue regarding the substantive issues of the assessment.

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH : BANGALORE

Before: SHRI PRASHANT MAHARISHI, VICE – & SHRI SOUNDARARAJAN K.

For Appellant: Shri Dhiraj, CA

For Respondent: Dr. Divya K., JCIT-DR

IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH : BANGALORE

BEFORE SHRI PRASHANT MAHARISHI, VICE – PRESIDENT AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER

IT(IT)A No. 813/Bang/2025 Assessment Year : 2022-23

M/s. KIA Corporation, The Assistant C/o. KIA India Pvt. Ltd., Commissioner of Erramanchi, Income Tax, Penukonda Mandal, International Anantapur Dist., Taxation – 1(2), Andhra Pradesh – 515 164. Vs. Bangalore. PAN: AAHCK3540K APPELLANT RESPONDENT

Assessee by : Shri Dhiraj, CA Revenue by : Dr. Divya K., JCIT-DR

Date of Hearing : 16-06-2025 Date of Pronouncement : 11-09-2025

ORDER PER SOUNDARARAJAN K., JUDICIAL MEMBER

This is an appeal filed by the assessee challenging the order of the Ld.ACIT, International Taxation, Intl Taxation Circle 1(2), Bangalore dated 22/01/2025 in respect of the A.Y. 2022-23.

At the time of hearing, we were informed that another appeal in respect of the very same Assessment Year and also against very same assessment order which was filed through e-filing was also registered as IT(IT)A No. 644/Bang/2025 and it got disposed off on 30/06/2025.

Page 2 of 2 IT(IT)A No. 813/Bang/2025 3. The present appeal also relates to the same AY and also against the very same assessment order which was filed in physical form and numbered as IT(IT)A No. 813/Bang/2025..

We have verified the said facts with the Registry and we were informed that the Registry had numbered the appeals filed through online as well as physically. Since the appeal in IT(IT)A No. 644/Bang/2025 was disposed off on 30/06/2025, we are not adjudicating the present appeal and dismiss the same as infructuous.

In the result, the appeal filed by the assessee is dismissed as infructuous.

Order pronounced in the open court on 11th September, 2025.

Sd/- Sd/- (PRASHANT MAHARISHI) (SOUNDARARAJAN K.) Vice – President Judicial Member

Bangalore, Dated, the 11th September, 2025. /MS /

Copy to: 1. Appellant 2. Respondent 3. CIT 4. DR, ITAT, Bangalore 5. Guard file 6. CIT(A) By order

Assistant Registrar, ITAT, Bangalore

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