M/S. MAA MAHAMAYA ROLLING MILL PVT. LTD., MAHASAMUND,MAHASAMUND vs. ACIT,CENTRAL CIRCLE-2, RAIPUR, RAIPUR

ITA 683/RPR/2026Status: HeardITAT Raipur12 October 2026AY 2014-1511 pages

AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the Ld. CIT(Appeals) had passed an ex-parte order due to the assessee's non-compliance, despite providing several opportunities. The Tribunal, respectfully following its previous decisions in Brajesh Singh Bhadoria and Collector Mining, Kondagaon, set aside the order of the Ld. CIT(Appeals). The matter was remanded back to the file of the Ld. CIT(Appeals)/NFAC for denovo adjudication on merits, while complying with the principles of natural justice. The Tribunal directed that this be a final opportunity for the assessee to comply with hearing notices and represent the matter on merits. The Ld. CIT(Appeals) was instructed to consider the assessee's submissions and pass a speaking order in terms with Section 250(4) & (6) of the Act. The grounds of appeal were allowed for statistical purposes. The Tribunal noted that while legal issues can be raised at any appellate forum as per National Thermal Power Company Ltd. Vs. CIT, the present case involved principles of natural justice and an ex-parte order, necessitating a remand rather than adjudication of the legal ground by the ITAT.

What were the facts?

The assessee, M/s. Maa Mahamaya Rolling Mill Pvt. Ltd., filed an appeal before the ITAT, Raipur Bench, against the order of the Ld. CIT(Appeals), Raipur-3, for Assessment Year 2014-15. The Ld. CIT(Appeals) had dismissed the assessee's appeal ex-parte due to non-compliance, despite several opportunities for hearing and submission of replies. The assessee failed to provide detailed explanations regarding the grounds of appeal. The Ld. Sr. DR submitted that the matter should be remanded back to the Ld. CIT(Appeals)/NFAC for denovo adjudication in the interest of natural justice, citing previous ITAT decisions.

What were the issues?

1. Whether the Ld. CIT(Appeals) was justified in dismissing the assessee's appeal ex-parte due to non-compliance, without adjudicating on merits? (Question of law and fact, turning on principles of natural justice and Section 250(4) & (6) of the Income Tax Act, 1961). Assessee's Contention: Not explicitly recorded in the judgment, but the appeal itself implies a challenge to the ex-parte order and a desire for adjudication on merits. Revenue's Contention: The Ld. Sr. DR argued that the matter should be remanded back to the Ld. CIT(Appeals)/NFAC for denovo adjudication in the interest of natural justice, citing the ITAT decisions in Brajesh Singh Bhadoria Vs. Dy./ACIT and Collector Mining, Kondagaon Vs. Deputy Commissioner of Income Tax (TDS).

Which sections of the Income-tax Act were involved?

Section 250(4),Section 250(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH “SMC”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY

For Appellant: Shri Sunil Kumar Agrawal &, Ms. Vidya Verma, CAs

For Respondent: Shri Piyush Tripathi, Sr. DR

Hearing: 12.10.2026Pronounced: 12.10.2026

PER PARTHA SARATHI CHAUDHURY, JM

The present appeal preferred by the assessee emanates from the order of the Ld.CIT(Appeals), Raipur-3, dated 08.07.2026 for the assessment year 2014-15 as per the grounds of appeal on record.

At the very outset, it is noted that as evident from Para 3.1 of the impugned order, the Ld.CIT(Appeals) vide a

The order continues below.

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