54 orders · Page 2 of 2
The Tribunal dismissed the appeal in limine due to the assessee's non-representation and failure to cure defects. The assessee was granted liberty to seek recall if a reasonable cause for non-representation could be shown.
The Tribunal held that the CIT(A) failed to properly adjudicate the assessee's objections regarding the validity of the Section 148 notice. The CIT(A) should have examined the record to verify the approval for the notice instead of placing the burden on the assessee.
The Tribunal found the reasons for delay insufficient and considered them an afterthought. The Tribunal noted the assessee's lack of diligence in pursuing appeals before both the CIT(A) and the ITAT.
The Tribunal dismissed the Revenue's appeal. This was based on a CBDT circular that set a monetary limit for appeals, and the tax effect in this case was below that limit.