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Income Tax Appellate Tribunal, COCHIN BENCH, COCHIN
Before: Shri Satbeer Singh Godara & Shri Amarjit Singh
IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN
Before Shri Satbeer Singh Godara, Judicial Member and Shri Amarjit Singh, Accountant Member
ITA Nos. 760 to 763/Coch/2023 (Assessment Years: 2011-12, 2014-15, 2016-17 & 2017-18)
Global Wave Technologies Pvt. Ltd. Income Tax Officer SDF, 17, 4th Floor, Cochin Sez Corporate Circle 1(2) vs. Kakkanad, Cochin 682037 Kochi [PAN: AADCG1637M] (Appellant) (Respondent)
Appellant by: Shri Mathew Joseph, CA Respondent by: Smt. V. Swarnalatha, Sr. D.R.
Date of Hearing: 16.08.2024 Date of Pronouncement: 23.10.2024
O R D E R Per Bench
These assessee’s four appeals arise against orders of the National Faceless Appeal Centre , Delhi [CIT(A)] in proceedings u/s. 250 of the Income Tax Act, 1961 (the Act) as under : -
Sr. ITA No. AY DIN & Order No. Date No. 1 760/Coch/2023 2011-12 ITBA/NFAC/S/250/2023- 31.08.2023 24/1055615258(1) 2 761/Coch/2023 2014-15 ITBA/NFAC/S/250/2023- 31.08.2023 24/1055628072(1) 3 762/Coch/2023 2016-17 ITBA/NFAC/S/250/2023- 31.08.2023 24/1055631568(1) 761/Coch/2023 2017-18 ITBA/NFAC/S/250/2023- 31.08.2023 24/1055634609(1) Heard both the parties. Case files perused.
2 ITA Nos. 760 to 763/Coch/2023 Global Wave Technologies Pvt. Ltd. 2. It emerges during the course of hearing with the able assistance coming from both the parties that the lower authorities have invoked section 40A(ia) and similar other disallowance(s); involving varying sums, in all these assessment years during the course of regular assessment(s) as upheld in the corresponding CIT(A)’s lower appellate discussion. A perusal of the latter’s respective findings reveals that in any of the impugned orders under challenge before us, the CIT(A)/NFAC, as the case may be, has neither framed any point of determination nor made a detailed adjudication thereupon on the assessee’s elaborate submissions made before him. Learned A.R. further seeks to butters the point that all the relevant lower appellate findings challenged before us have simply extracted the assessment findings and the assessee’s written submission than recording any specific finding on various issues raised therein.
Faced with this situation, we refrain ourselves from deciding the assessee’s instant appeals on merits and deem it appropriate in the larger interest of justice to remand their substantive grounds back to the CIT(A) for its afresh appropriate adjudication within three effective opportunities of hearing. Ordered accordingly.
This assessee’s four appeals ITA.Nos.760 to 763/Coch./2023 are allowed for statistical purposes in above terms. A copy of this common order be placed in the respective case files.
Order pronounced in the open court on 23rd October, 2024 under Rule 34 of The Income Tax (Appellate Tribunal) Rules, 1963. Sd/- Sd/- (Amarjit Singh) (Satbeer Singh Godara) Accountant Member Judicial Member Cochin, Dated: 23rd October, 2024 n.p.
3 ITA Nos. 760 to 763/Coch/2023 Global Wave Technologies Pvt. Ltd.
Copy to:
The Appellant 2. The Respondent 3. The Pr. CIT concerned 4. The Sr. DR, ITAT, Cochin 5. Guard File By Order
Assistant Registrar ITAT, Cochin