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Facts
The assessee, GRD Finance Pvt. Ltd., filed appeals against orders of the CIT(A) concerning assessment years 2011-12 to 2013-14 and 2017-18. The appeals involved common issues, including challenges to reopening and reassessment on technical grounds.
Held
The Tribunal noted that the technical grounds regarding reopening and reassessment were not raised before the CIT(A). Therefore, the issues were restored to the CIT(A) for readjudication after providing the assessee with an opportunity to be heard.
Key Issues
Whether the appeals raising technical grounds on reopening and reassessment, not previously raised before the CIT(A), should be considered.
Sections Cited
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Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI
Before: SHRI GEORGE MATHAN & SHRI RATNESH NANDAN SAHAY
Assessee represented by Shri Sunil Surana, A.R. Department represented by Shri R.C. Marndi, Sr. DR Date of hearing 07/01/2026 Date of pronouncement 07/01/2026 O R D E R PER: BENCH 1. These are the appeals filed by the assessees against the separate orders of the ld. CIT(A), NFAC, Delhi all dated 08/10/2024 for the A.Y. 2011-12 to 2013-14 and 2017-18 respectively. As all the issues in all these appeals relate to the common issues, therefore, they are being disposed off by this common order.
Shri Sunil Surana, ld. AR is represented on behalf of the assessee and Shri R.C. Marndi, ld. Sr. DR is represented on behalf of revenue.
In the grounds raised
by the assessee, the assessee has challenged the reopening and the reassessment and has raised technical grounds. It is noticed that these grounds were not before the ld. CIT(A). As these issues were not before the ld. CIT(A) so as to get the findings of the ld. CIT(A) on to 478/Ran/2024 GRD Finance Ltd. Vs ITO these grounds. Therefore, the issues in all these appeals are restored to the file of ld. CIT(A) for readjudication after granting the assessee adequate opportunity of being heard.
4. In the result, all these appeals of the assessees are partly allowed for statistical purposes. Order pronounced in open court on 07th January, 2026.