Satanarayan Ispat Private Limited Vs ITO (ITAT Kolkata)
CIT(A) Cannot Dismiss Appeal Merely for Non-Compliance; All Grounds Must Be Decided on Merits: ITAT Kolkata
Summary: The Kolkata Bench of the Income Tax Appellate Tribunal has held that even where an assessee fails to participate properly in the first appellate proceedings, the CIT(A) cannot dismiss the appeal without deciding all the grounds raised by the assessee on merits.
The assessee, Satanarayan Ispat Private Limited, was subjected to reassessment proceedings for Assessment Year 2019-20. The assessment was completed under section 147 read with section 144B of the Income-tax Act, 1961, on 18.03.2025 by making certain additions.
Aggrieved by the reassessment order, the assessee filed an appeal before the CIT(A), NFAC. The CIT(A), however, dismissed the appeal through an ex parte order dated 02.06.2026.
The assessee carried the matter before the Tribunal and contended that the CIT(A) had not provided a proper opportunity of hearing. It was argued that the appeal had been dismissed in violation of the principles of natural justice and without properly adjudicating the grounds raised against the additions made by the Assessing Officer.
The Revenue relied upon the order of the CIT(A) and sought dismissal of the assessee’s appeal.
