Mehi Power Transformers Vs DCIT (ITAT Indore)
Income Tax Appellate Tribunal (ITAT) Indore Bench has remanded an appeal filed by Mehi Power Transformers back to the Commissioner of Income Tax (Appeals) [CIT(A)] for de novo adjudication. The Tribunal’s decision was based on its finding that the CIT(A) had failed to consider the assessee’s detailed reply and accompanying documents, leading to an order passed in violation of the principles of natural justice.
The case pertains to the Assessment Year 2018-19. The assessee’s total income was initially assessed at Rs. 1,08,56,463/-, an increase from the returned income of Rs. 82,13,230/-, resulting in an addition of Rs. 26,43,233/- by the Assessing Officer (AO) via an assessment order dated March 29, 2021, passed under Section 144 read with Section 143(3A) and 143(3B) of the Income Tax Act, 1961.
Aggrieved by this assessment, Mehi Power Transformers filed a first appeal before the CIT(A). However, the CIT(A), in an order dated December 20, 2024, dismissed the appeal, primarily stating that the assessee had not filed any documents to support its claims, despite being given three opportunities.
Before the ITAT, the assessee contended that the CIT(A)’s order was “bad in law, illegal, and not proper” and violated natural justice principles. The learned Authorized Representative (AR) for the assessee provided proof, including an e-proceedings response acknowledgement dated December 2, 2024, demonstrating that an exhaustive reply along with supporting documents had indeed been uploaded to the portal and submitted to the CIT(A). The AR highlighted that the CIT(A) had erroneously recorded, “However, the appellant has not filed any documents with reply dated 02.12.2024,” which directly contradicted the submitted proof.
