In a landmark case, ITA No. 1479/DEL/2022, the Income Tax Appellate Tribunal (ITAT) Delhi Bench ‘G’, chaired by Dr. B. R. R. Kumar, Accountant Member, and Ms. Astha Chandra, Judicial Member, delivered a judgment that has drawn significant attention in the domain of tax litigation in India. The case pertains to Sadhna Goyal, a resident of ED 9C, Pitampura, Madhuban Chowk, New Delhi, who filed an appeal against the order of the ld. Commissioner of Income Tax (Appeals) [CIT(A)]-26, New Delhi, dated 09.06.2022, concerning the assessment year 2017-18.
Presented before the tribunal were grievances against the order passed by the CIT(A), which Sadhna Goyal contended was unjust both in terms of legal standing and factual accuracy. The grounds of appeal raised pointed towards procedural discrepancies as well as substantive misjudgments, including the ex-parte decision without giving adequate opportunity for the appellant to be heard, violation of natural justice principles, and unwarranted additions to the declared income.
The appellant’s counsel, Sh. Uma Upadhyay, CA, and the respondent’s counsel, Sh. H. K. Choudhary, CIT DR, presented their cases on 03.04.2023, leading to a pronouncement on 30.06.2023. The tribunal meticulously examined the records, the appeal grounds, and the arguments presented by both sides. It was observed that the appellate authority had summarily confirmed the assessing officer’s additions without delving into the merits of the case, based on the appellant’s non-compliance with hearing notices.
The ITAT, acknowledging the criticality of adjudicating cases on their merits, remanded the matter back to the file of the ld. CIT(A) for a comprehensive review. The tribunal underscored the importance of providing the appellant an opportunity to submit her case in detail, thereby ensuring that justice is served while also maintaining the procedural sanctity of the income tax assessment process.
Dr. B. R. R. Kumar and Ms. Astha Chandra, in their ruling, allowed the appeal for statistical purposes, a decision that indirectly emphasizes the tribunal’s disposition towards ensuring fairness and equity in tax adjudication processes. This case highlights the tribunal’s role in bridging gaps between taxpayers and the authorities, ensuring that every case is heard and judged on its individual merits and facts.
The verdict, pronounced in the open court on 30/06/2023, set a precedence in handling cases where procedural lapses potentially overshadow the factual basis of appeals. It reiterates the principle that justice must not only be done but seen to be done, marking a significant step towards upholding the rights of taxpayers within the framework of equitable and just tax law administration.
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The detailed examination of the appeals, the points of law involved, and the procedural aspects covered in this case reflect the complexity and nuances of tax litigation in India. In essence, the appeal by Sadhna Goyal against the CIT(A)’s order for the assessment year 2017-18 underscores the imperative of thoroughness, fairness, and adherence to principles of natural justice within the realm of tax adjudication.
