Facts of the Case
The assessee, Pinku, filed an appeal before the Commissioner
(Appeals) against the assessment order. The CIT(A) disposed of the appeal
ex-parte due to non-appearance or alleged non-compliance by the assessee and
dismissed the appeal without adjudicating the grounds on merits.
The assessee contended that adequate opportunity of hearing
was not provided and that there were reasonable causes for non-appearance.
Aggrieved by the dismissal, the assessee preferred an appeal before the
Tribunal.
Issues Involved
- Whether
the ex-parte dismissal of the appeal by the CIT(A) was legally
sustainable.
- Whether
the assessee was denied reasonable opportunity of being heard.
- Whether
the matter should be restored for fresh adjudication on merits.
Petitioner’s (Assessee’s) Arguments
- The
assessee submitted that the appeal was dismissed without granting
effective opportunity of hearing.
- Non-appearance
occurred due to bona fide reasons.
- The
issues raised in appeal were not examined on merits.
- The
order violated principles of natural justice.
Respondent’s (Revenue’s) Arguments
- The
Department contended that sufficient opportunities had been granted.
- The
assessee failed to comply with notices issued by the appellate authority.
- The
CIT(A) was justified in deciding the appeal based on available records.
Court Order / Findings (ITAT)
- The
appeal was disposed of without adjudicating the issues on merits.
- Effective
and reasonable opportunity of hearing must be provided before passing an
adverse order.
- Principles
of natural justice are fundamental to appellate proceedings.
Important Clarification by the Tribunal
- Appeals
should ordinarily be decided on merits rather than dismissed for
non-prosecution.
- Procedural
fairness is mandatory in quasi-judicial proceedings.
- Orders
passed without proper opportunity are liable to be annulled or remanded.
Link to download the order – https://itat.gov.in/public/files/upload/1574673639-PINKU-189(CITA).pdf
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