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

ITA 1496/CHNY/2024Status: DisposedITAT Chennai26 May 2025AY 2018-19Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI S.R.RAGHUNATHA (Accountant Member)1 pages
AI SummaryAllowed

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)

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(2)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

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.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 154

All 8,676 judgments and leading authorities on Section 154 →

Recent GST High Court judgments

Search GST case law →