Case Law Details
Umrao Singh Smarak Samiti Vs ITO-CPC (ITAT Allahabad)
ITAT Allahabad held that passing an ex-parte appellate order without providing any opportunity even in case of faceless assessment proceedings unjustified as adherence to Principles of natural justice is one of the most important pillar of the effective judicial delivery system.
Facts- The assessee filed ROI which was processed by CPC , Bangalore u/s. 143(1), wherein income of the assessee was assessed at Rs. 94,60,424/- as against ‘NIL’ income declared by the assessee.
CPC Bangalore denied the benefit of deduction u/s 11 and 12 of the 1961 Act, wherein claim of the assessee for application of income to the tune of Rs. 1,26,66,292/- was denied/rejected by CPC, Bangalore. The assessee filed rectification application u/s 154 of the 1961 Act , dated 13.07.2020 . The aforesaid rectification application filed by assessee was dismissed by CPC, Bangalore, vide rectification order dated 10.08.2020 passed by CPC, Bangalore u/s 154, wherein income of the assesses was again computed at Rs. 94,60,424/- .
The assessee being aggrieved by rectification order dated 10.08.2020 passed by CPC , Bangalore u/s 154, filed first appeal before ld. CIT(A), who dismissed the appeal of the assessee. Being aggrieved, the present appeal is filed.
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