SAR AUTO PRODUCTS LIMITED,RAJKOT vs. ACIT CIRCLE 1(2), RAJKOT, RAJKOT

ITA 668/RJT/2025Status: DisposedITAT Rajkot12 February 2026AY 2009-2010Bench: DR. ARJUN LAL SAINI (Accountant Member), DR. DINESH MOHAN SINHA (Judicial Member)6 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the second appellate order was void ab initio as the appeal for the same assessment year had already been decided by the jurisdictional CIT(A). The subsequent order constituted double adjudication and a jurisdictional error due to the appeal not being pending at the time of transfer to the faceless system.

What were the facts?

The assessee's appeal for AY 2009-10 against an assessment order was initially allowed by CIT(A)-1, Rajkot. Subsequently, the same appeal was again taken up and dismissed ex-parte by ADDL/JCIT(A)-12, Mumbai, under the faceless appeal system. The assessee challenged this second order, arguing double adjudication and jurisdictional error.

What were the issues?

The key legal issues were whether a second appellate order on the same cause of action constitutes double adjudication and jurisdictional error, especially when the appeal was already disposed of by a competent authority.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 147,Section 68,Section 69A,Section 234B,Section 234C,Section 271(1)(c),Section 246A,Section 250,Section 250(6B)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAJKOT BENCH, RAJKOT

Before: DR. ARJUN LAL SAINI & DR. DINESH MOHAN SINHA

For Appellant: Shri Gaurang Khakhar, Ld. A.R
For Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Hearing: 18/12/2025Pronounced: 12/02/2026

Per Dr. Dinesh Mohan Sinha, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY)-2009-10, is directed against the order passed by the Additional/JCIT Income Tax [(in short “Ld.JCIT”] vide order dated 12.09.2025, which in turn assessment order passed by Income Tax Department/Assessing Officer under section 143 r.w.s.147 of the Income Tax Act, 1961 (in short “the Act”), vide order dated 16.12.2016. 2. Grounds of appeal raised by the assessee are as follows:

“1. Double Adjudication: The impugned order constitutes double adjudication on the same ca

The order continues below.

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