Facts of the Case
The assessee filed an appeal before the Commissioner (Appeals)
challenging the assessment order. The CIT(A), however, disposed of the appeal
ex-parte due to non-appearance or alleged non-compliance by the assessee and
dismissed the appeal without adjudicating the issues on merits.
The assessee contended that adequate opportunity of being
heard was not provided and that there were valid reasons for non-appearance.
Aggrieved by the dismissal, the assessee approached the Tribunal.
Issues Involved
- Whether
the ex-parte dismissal of the appeal by the CIT(A) was legally valid.
- 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.
- Non-appearance
was due to reasonable and bona fide circumstances.
- The
issues raised in appeal were not examined on merits.
- Violation
of principles of natural justice rendered the order invalid.
Respondent’s (Revenue’s) Arguments
- The
Department contended that sufficient opportunities were granted.
- The
assessee failed to comply with notices issued by the appellate authority.
- The
CIT(A) was justified in deciding the matter based on available records.
Court Order / Findings (ITAT)
- The
appeal had been disposed of without proper consideration of the issues on
merits.
- Adequate
and effective 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
- Appellate
authorities must decide appeals on merits wherever possible.
- Dismissal
for non-prosecution without examining issues is not appropriate.
- Proper
opportunity of hearing is a mandatory procedural requirement.
Link to download the order – Separate Source Link
(as requested):
https://itat.gov.in/public/files/upload/1574659386-AJAY-12(CITA).pdf
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