MANAGER BETTIAH ESTATE UNDER COURT OF WARD,RAJ COMPOUND, BETTIAH, WEST CHAMPARAN vs. INCOME TAX OFFICER, WARD 5(1), BETTIAH, STATION ROAD, SUPRIYA CINEMA ROAD, BETTIAH

ITA 348/PAT/2026Status: DisposedITAT Patna08 October 2026AY 2018-199 pages
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What did the Tribunal hold?

The Tribunal noted that the assessee's cases were completed ex-parte at both the assessment and first appellate levels. Considering the submissions of the assessee's counsel, the prayer for an additional opportunity, and in the interest of natural justice, the Tribunal decided to remit the issues back to the file of the Assessing Officer for fresh consideration and decision. The assessee was directed to substantiate its case with cogent documents and avoid seeking unnecessary adjournments. A cost of Rs. 20,000/- for both years was imposed on the assessee for disrespecting Income Tax proceedings. The Tribunal cautioned that no further leniency would be granted if the assessee failed to comply. The appeals were allowed for statistical purposes.

What were the facts?

The assessee, Manager Bettiah Estate Under Court of Ward, filed two appeals (ITA Nos. 348 & 349/PAT/2026) before the ITAT against the orders of the National Faceless Appeal Centre (NFAC), Delhi, for Assessment Years 2018-19 and 2019-20. The appeals were delayed by 48 days, which the Tribunal condoned due to reasonable cause. The original assessments were made under Section 147/144 r.w.s. 144B of the Income Tax Act, 1961, after the assessee failed to file returns in response to notices under Section 148, despite having substantial transactions and cash deposits. The Assessing Officer (AO) completed the assessments ex-parte, determining income at Rs. 27,28,62,992/- for AY 2018-19 and Rs. 2,21,28,950/- for AY 2019-20. The assessee's appeals before the Ld. CIT(A) were also rejected for failing to controvert the AO's findings.

What were the issues?

1. Whether the Tribunal should condone the delay of 48 days in filing the appeals by the assessee, considering the reasons provided. (Question of procedure) 2. Whether the assessee's case, which was completed ex-parte at the assessment and first appellate stages due to non-representation and failure to substantiate claims with cogent documents, warrants a fresh opportunity for adjudication. (Question of mixed law and fact, turning on principles of natural justice and procedural fairness under the Income Tax Act, 1961). Assessee's Contentions: - The assessee's counsel submitted that the assessee could not represent its case effectively during the reassessment proceedings and before the Ld. CIT(A), failing to substantiate its case with cogent documents. - A request was made for one more chance to be granted to the assessee, given that the assessment was completed ex-parte under Section 144/147. Revenue's Contentions: - The learned DR relied on the orders of the lower authorities and did not raise serious objections.

Which sections of the Income-tax Act were involved?

Section 250,Section 147,Section 144,Section 144B,Section 139,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA BENCH, PATNA

For Appellant: Shri Anup Kumar, Adv
For Respondent: Shri Bharat Bhushan Garg, CIT-DR
Hearing: 20.07.2026Pronounced: 08.10.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

These two appeals filed by the against the orders passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “the Ld. CIT(A)], dated 27.01.2026, DIN & order No. ITBA/NFAC/S/250/2025-26/1085163824(1) and ITBA /NFAC /S/250/2025-26/1085163960(1) respectively on the following grounds of appeal:

Manager Bettiah Estate Under Court of Ward Manager Bettiah Est

The order continues below.

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