In M/s KRVM Jewels
v. Income Tax Officer, Ward 51(5), Delhi (ITAT Delhi, order dated 09
January 2026), the Delhi Bench of the Income Tax Appellate Tribunal considered
the assessee’s appeal for Assessment Year 2017-18 against an ex parte order
passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal
Centre, under Section 250 of the Income-tax Act, 1961, arising from an
assessment completed under Section 143(3).
The Tribunal first
addressed the issue of delay of 580 days in filing the appeal. Accepting
the assessee’s explanation that the delay occurred due to lack of knowledge of
the impugned appellate order, and noting the absence of any mala fide intent or
undue advantage, the Tribunal condoned the delay in the interest of justice.
On merits, it was
observed that the Commissioner (Appeals) had passed the impugned order ex
parte, as the assessee had not filed submissions in support of the grounds
of appeal. The assessee sought restoration of the matter, and the Revenue
raised no objection. The Tribunal held that passing an appellate order without
affording an effective opportunity of hearing is contrary to the principles
of natural justice.
Accordingly, the
Tribunal set aside the ex parte order of the Commissioner (Appeals) and
restored the matter to the file of the first appellate authority for fresh
adjudication in accordance with law, after providing the assessee a fair
and reasonable opportunity of being heard. The appeal was allowed for statistical
purposes.
Source Link- https://itat.gov.in/public/files/upload/1767948726-g7N3rh-1-TO.pdf
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