JAJOO RASHMI REFRACTORIES LIMITED,JAIPUR vs. RJN-C-(104)(1), DCIT CIRCLE-4, JAIPUR

PDF · subscribers
ITA 225/JPR/2026Status: DisposedITAT Jaipur26 October 2026AY 2020-213 pages
AI SummaryWithdrawn

What did the Tribunal hold?

The Tribunal noted the assessee's written application seeking withdrawal of the appeal. The application detailed that subsequent rectification proceedings under Section 154 of the Income Tax Act, 1961, had resulted in the grant of consequential relief, a refund of ₹12,00,219, and correction of the assessed income to ₹3,48,85,450. The assessee stated that no substantive grievance survived for adjudication. The learned Departmental Representative had no objection to the withdrawal. In light of these submissions, the Tribunal held that the appeal should be dismissed as withdrawn. The Tribunal did not decide on the merits of the original grievance regarding Section 10AA deduction, as the appeal was withdrawn.

What were the facts?

The assessee, Jajoo Rashmi Refractories Limited, filed an appeal before the Income Tax Appellate Tribunal (ITAT), Jaipur Bench, against an order passed by the National Faceless Appeal Centre (NFAC), Delhi, for Assessment Year 2020-21. The appeal challenged the non-grant of deduction claimed under Section 10AA of the Income Tax Act, 1961. During the pendency of the appeal, the assessee filed an application seeking withdrawal. The application stated that subsequent rectification proceedings under Section 154 of the Act by the Assessing Officer had granted the necessary consequential relief, resulting in a refund of ₹12,00,219 and correction of the assessed income to ₹3,48,85,450. Consequently, no substantive grievance remained for adjudication.

What were the issues?

1. Whether the assessee's appeal against the order of the NFAC, Delhi, concerning the non-grant of deduction under Section 10AA of the Income Tax Act, 1961, for AY 2020-21, should be permitted to be withdrawn as infructuous. Assessee's Contention: The assessee argued that subsequent rectification proceedings under Section 154 of the Act had resolved the issue, leading to the grant of consequential relief and a refund. Therefore, no substantive grievance survived, and the appeal should be dismissed as withdrawn/infructuous. The assessee sought to withdraw the appeal without prejudice to its right to pursue the release of the determined refund and consequential interest under Section 244A. Revenue's Contention: The learned Departmental Representative (DR) had no objection to the withdrawal of the appeal by the assessee.

Which sections of the Income-tax Act were involved?

Section 10AA,Section 154,Section 244A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR BENCHES, “A” BENCH, JAIPUR

Before: SMT. ANNAPURNA GUPTA & SHRI KULDIP SINGH

Hearing: 22.10.2026Pronounced: 26.10.2026

Per Annapurna Gupta, AM:- The present appeal has been filed by the assessee against the order passed by the National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “Ld. CIT(A)”), dated 10.12.2025 under

P a g e | 2 ITA No. 225/JPR/2026 Jajoo Rashmi Refractories Limited Section 12AB of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). 2. During the course of hearing before us, learned counsel for the assessee filed an application in writing seeking withdrawal of the appeal. The contents of the application read as under:-

1.

That the above appeal filed by the Appellant is fixed for hearing before the Hon'ble Bench on 22.10.2026.

2.

That the appeal arose from the order passed by the learned Commissioner of Income-tax (Appeals)/NFAC for A.Y. 2020-21 in relation to the addition/disallowance arising on account of non-grant of the deduction claimed under section 10AA of the Income-tax Act, 1961.

3.

That subsequently, during the rectification proceedings under section 154 of the Income-tax Act, 1961, the Assessing Officer has granted the necessary consequential relief. The Department has also recorded that the rectification order resulted in creation of a refund of ₹12,00,219, and the assessed income has ultimately been corrected to 3,48,85,450, being the returned income.

4.

That, consequently, no substantive grievance survives for adjudication in the present appeal, and the Appellant therefore does not wish to pursue the appeal any further.

5.

The Appellant accordingly most respectfully seeks permission of the Hon'ble Bench to withdraw the present appeal and dismiss the same as withdrawn/infructuous.

6.

The withdrawal of the present appeal may kindly be treated without prejudice to the Appellant's right to pursue release of the refund already determined by the Department together with consequential interest, if any, admissible under section 244A of the Income-tax Act, 1961.

P a g e | 3 ITA No. 225/JPR/2026 Jajoo Rashmi Refractories Limited 3. Ld. DR had no objection to the withdrawal of appeal by the assessee. In view of the above the appeal of the assessee is dismissed as withdrawn. Order pronounced in the Open Court on 26.10.2026

Sd/- Sd/- (Kuldip Singh) (Annapurna Gupta) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated 26.10.2026 Mittali, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT

By Order, Asst. Registrar ITAT, Jaipur

More judgments on Section 10AA

All 857 judgments and leading authorities on Section 10AA →

Recent GST High Court judgments

Search GST case law →