Facts of the Case
The assessee filed an appeal before
the Income Tax Appellate Tribunal, Allahabad Bench, for Assessment Year 2010-11
against the appellate order dated 21.03.2025 passed by the Commissioner of
Income Tax (Appeals). Upon filing of the appeal, the Registry of the Tribunal
issued a defect memo dated 28.05.2025 pointing out that the memorandum of
appeal was not signed by the appellant and that the uploaded Form-36 was
incomplete and missing pages.
Despite lapse of substantial time
after issuance of the defect memo, the assessee failed to remove the defects.
Issues Involved
- Whether an appeal can be admitted when mandatory
procedural defects remain unrectified.
- Whether failure to comply with Registry-pointed
defects justifies dismissal of appeal in limine.
- Whether liberty can be granted to the assessee
for restoration of appeal after curing defects.
Petitioner’s Arguments
No effective compliance or
rectification of defects was made by the assessee despite issuance of defect
memo by the Registry. Consequently, no submissions on merits were placed before
the Tribunal.
Respondent’s Arguments
The learned Departmental
Representative relied upon procedural compliance requirements and supported
dismissal of the appeal due to non-removal of defects.
Court Order / Findings
The Tribunal observed that despite
sufficient time having elapsed since issuance of the defect memo, the assessee
failed to remove the defects pointed out by the Registry. The Tribunal held
that compliance with procedural requirements such as signing of memorandum of
appeal and submission of complete Form-36 is mandatory for valid institution of
appeal.
Important Clarification
The Tribunal clarified that the
dismissal was purely on account of procedural non-compliance and not on merits.
The assessee was expressly granted liberty to approach the Tribunal for
restoration of the appeal after removing the defects, and any such request
would be considered in accordance with law and relevant facts.
Link to download the order - https://www.mytaxexpert.co.in/uploads/1770626697_POOJAPALSULEMSARAIALLAHABADVS.ITO21ALLAHABADALLAHABAD.pdf
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