ILJIN AUTOMOTIVE PRIVATE LIMITED,IRUNGATTUKOTTAI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE 1(1), ),, CHENNAI

ITA 1495/CHNY/2024Status: DisposedITAT Chennai26 May 2025AY 2017-18Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI S.R.RAGHUNATHA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the Assessing Officer (AO) failed to provide the assessee with a reasonable opportunity of being heard before passing the rectification orders, which enhanced the assessment. This violation of statutory procedure under Section 154(3) rendered the rectification orders invalid.

What were the facts?

The assessee company filed appeals challenging rectification orders passed under Section 154 of the Income Tax Act. The core issue was the alleged violation of natural justice due to the absence of a proper opportunity to be heard before the rectification orders were passed.

What were the issues?

Whether rectification orders passed under Section 154 are valid when the mandatory notice and opportunity of hearing to the assessee were not provided, thereby violating principles of natural justice.

Which sections of the Income-tax Act were involved?

Section 154,Section 143(3),Section 155(4)

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI S.R.RAGHUNATHA

Hearing: 16.04.2025Pronounced: 26.05.2025

PER ABY T. VARKEY, JM: These are appeals preferred by the assessee company against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC,

(hereinafter referred to as “the Ld.CIT(A)”), Delhi, all dated 19.03.2024

for the Assessment Years (hereinafter referred to as "AY”) 2016-17 to 2018-19. ITA Nos.1494 to 1496/Chny/2

The order continues below.

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