GRD Finance Pvt. Ltd. Vs ITO (ITAT Ranchi)
Reopening Grounds Not Examined by CIT(A): ITAT Restores Multiple Appeals for Fresh Adjudication
The Ranchi Bench of the ITAT dealt with a batch of five appeals filed by GRD Finance Pvt. Ltd. for AYs 2011-12, 2012-13, 2013-14 and 2017-18. The assessee raised technical and jurisdictional grounds challenging the validity of reopening and reassessment proceedings.
The Tribunal observed that these crucial grounds had not been raised or adjudicated before the CIT(A), and therefore no findings were available on record. In the absence of such adjudication, the ITAT held that the matter required restoration to the first appellate authority.
Accordingly, all the appeals were set aside to the file of the CIT(A) for fresh adjudication on the reopening and reassessment issues after granting the assessee adequate opportunity of being heard. The appeals were thus partly allowed for statistical purposes
FULL TEXT OF THE ORDER OF ITAT RANCHI
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.
