Mahadevan Vs ITO (ITAT Chennai)
The case of Mahadevan Vs ITO (ITAT Chennai) pertains to an appeal against an order by the Commissioner of Income Tax (Appeals), National Faceless Appeal Center (NFAC), for the assessment year 2019-20. The appellant challenged the ex-parte order dated June 26, 2024, alleging that the NFAC failed to consider the written submissions provided during the proceedings. Specifically, the assessee contended that sufficient details had been submitted to substantiate the cash deposits made during the demonetization period as part of an organized business activity. However, the NFAC claimed that no such details were filed. The appellant highlighted an electronic acknowledgment, dated March 21, 2024, proving submission of these details, and requested the case be remanded for fresh consideration.
After reviewing the submissions and available evidence, the ITAT noted that the NFAC had overlooked the material provided by the assessee. Consequently, the ITAT set aside the NFAC’s order and directed a de novo adjudication of the appeal. The appellate authority was instructed to thoroughly examine the details and issue a speaking order after providing the assessee with a fair opportunity to present their case. The responsibility for compliance with future notices was placed on the assessee, with a warning of adverse consequences for non-compliance. The appeal was allowed for statistical purposes, emphasizing procedural fairness in tax proceedings.
