GRD FINANCE PVT LTD,KOLKATA vs. INCOME TAX OFFICER, WARD 1(1), RANCHI, INCOME TAX DEPARTMENT, CENTRAL REVENUE BUILDING

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ITA 476/RAN/2024Status: DisposedITAT Ranchi07 January 2026AY 2013-14Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)2 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal noted that these grounds were not raised before the CIT(A). Therefore, the issues were restored to the file of the CIT(A) for readjudication after providing the assessee an adequate opportunity of being heard.

What were the facts?

The appeals were filed by GRD Finance Pvt. Ltd. against the orders of the CIT(A) for assessment years 2011-12 to 2013-14 and 2017-18. The grounds raised by the assessee concerned the challenge to reopening and reassessment proceedings on technical grounds.

What were the issues?

Whether the grounds challenging reopening and reassessment, not raised before CIT(A), should be adjudicated by the Tribunal or restored to CIT(A).

Which sections of the Income-tax Act were involved?

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: SHRI GEORGE MATHAN & SHRI RATNESH NANDAN SAHAY

For Appellant: Shri Sunil Surana, A.R
For Respondent: Shri R.C. Marndi, Sr. DR
Hearing: 07/01/2026Pronounced: 07/01/2026

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.

2.

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.

3.

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.

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