DABUR INDIA LIMITED,DELHI vs. ACIT/DCIT, DELHI

ITA 3085/DEL/2025Status: DisposedITAT Delhi10 December 2025AY 2021-226 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(A) erred in dismissing the appeal as infructuous because the Assessing Officer, in the scrutiny assessment, did not address the grievances raised by the assessee against the 143(1) intimation. Therefore, the 143(1) order did not merge with the 143(3) assessment.

What were the facts?

The assessee's appeal against an order under section 143(1) was dismissed by the CIT(A) as infructuous due to merger with the subsequent assessment order under section 143(3). The assessee argued that the issues raised in the 143(1) order were not addressed in the scrutiny assessment.

What were the issues?

Whether an appeal against an order under section 143(1) is infructuous when a subsequent assessment order under section 143(3) is passed, and whether the issues raised in the 143(1) order were properly addressed in the scrutiny assessment.

Which sections of the Income-tax Act were involved?

Section 143(1),Section 143(3),Section 144C(3),Section 144B,Section 35,Section 115JB,Section 154

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCHES ‘C’: NEW DELHI.

For Appellant: Shri Chandan Agarwal, CA
For Respondent: Shri Dayainder Singh Sidhu, CIT DR
Hearing: 17.09.2025

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

The assessee has filed appeal against the order of the Learned Addl./JCIT (A), Kochi [“Ld. JCIT(A)”, for short] dated 17.03.2025 for the Assessment Year 2021-22 raising following grounds of appeal :- “1. That the Ld. CIT(A) has erred on facts and in law in holding that the appeal filed against order passed u/s 143(1) is infructuous as the order is merged with the assessment order passed u/s 143(3) r.w.s 144C(3) r.w.s 144B.

2.

That the order of the ld. CIT(A) is bad in law as no opportunity of being heard was granted to the appellant.

2

3.

Without prejudice to the ground number 1 and 2 above, the Ld. CIT failed to address the following issues on the merits of the case. 3a. The CPC has mechanically er

The order continues below.

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