HAZRAT FATEMA GIRLS HIGH SCHOOL,NANDED vs. CIT TDS NASHIK, NASHIK

ITA 2267/PUN/2025Status: DisposedITAT Pune23 January 2026Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)8 pages
AI SummaryRemanded

What did the Tribunal hold?

The ITAT held that the CIT(A) erred in dismissing the appeals without deciding on merits, especially when the assessee had clarified that the VSVS application was not accepted. The tribunal set aside the CIT(A)'s orders and remanded all five appeals back to the CIT(A) for de novo adjudication on merits, instructing them to grant a proper hearing and consider binding precedents, specifically regarding Section 234E for periods prior to 01.06.2015.

What were the facts?

The assessee filed five appeals against orders passed by the CIT(A) under Section 250 of the Income Tax Act. The assessee had applied for the Vivad Se Vishwas Scheme (VSVS) 2020 but was not issued Form 3 (acceptance), thus could not complete the process, and clarified to the CIT(A) that the VSVS application was not accepted due to the appeal filing date. However, the CIT(A) dismissed the appeals as "infructuous" or "for statistical purposes" without addressing the merits.

What were the issues?

Whether the CIT(A) was justified in dismissing appeals as infructuous due to an unaccepted VSVS application without deciding on merits; whether the cases should be remanded for fresh adjudication.

Which sections of the Income-tax Act were involved?

Section 250,Section 200A(1),Section 234E

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Heard together (4 matters)

ITA No.2255/PUN/2025
ITA No.2259/PUN/2025
ITA No.2264/PUN/2025
ITA No.2267/PUN/2025

Read from the judgment's own cause title. This page is filed under one of them.

आयकर अपीलीय अधिकरण ”ए” न्यायपीठ पुणेमें। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “A” :: PUNE BEFORE DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपऩल सं. / ITA No.2255/PUN/2025 निर्धारण वषा / Assessment Year: 2013-14 24Q Q4 Hazrat Fatema Girls High V CIT TDS, School, s Nashik. Irfan Nagar, Qudwai Nagar, Nanded – 431604. PAN: NSKHO1795D Appellant/ Assessee Respondent /Revenue

आयकर अपऩल सं. / ITA No.2259/PUN/2025 निर्धारण वषा / Assessment Year: 2015-16 24Q Q3 Hazrat Fatema Girls High V CIT TDS, School, s Nashik. Irfan Nagar, Qudwai Nagar, Nanded – 431604. PAN: NSKHO1795D Appellant/ Assessee Respondent /Revenue

आयकर अपऩल सं. / ITA No.2264/PUN/2025 निर्धारण वषा / Assessment Year: 2015-16 24Q Q2 Hazrat Fatema Girls High V CIT TDS, School, s Nashik. Irfan Nagar, Qudwai Nagar, Nanded – 431604. PAN: NSKHO1795D Appellant/ Assessee Respondent /Revenue

ITA Nos.2255, 2259, 2264, 2267 & 2268/PUN/2025 [A]

आयकर अपऩल सं. / ITA No.2267/PUN/2025 निर्धारण वषा / Assessment Year: 2015-16 24Q Q4 Hazrat Fatema Girls High V CIT TDS, School, s Nashik. Irfan Nagar, Qudwai Nagar, Nanded – 431604. PAN: NSKHO1795D Appellant/ Assessee Respondent /Revenue आयकर

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