The Income Tax Appellate Tribunal of Delhi, in a final tribunal order pronounced on May 2, 2023, addressed the appeal filed by the Deputy Commissioner of Income Tax, Central Circle-14, Delhi against Delhi Gurgaon Super Connectivity Pvt. Ltd. The case involved the assessment year 2014-15 and revolved around unexplained sundry creditors.
The appellant, DCIT, contested the decision of CIT(A) -26, New Delhi, which had favored the assessee, Delhi Gurgaon Super Connectivity Pvt. Ltd. The initial assessment order was revised under section 263 of the Income Tax Act by PCIT-2, New Delhi, leading to the addition of claims against unexplained sundry creditors. This revision was later quashed by ITAT Delhi C Bench on October 10, 2020, rendering the subsequent appeal by the revenue as infructuous.
During the hearing, the CIT DR acknowledged the quashing of the revisionary order, agreeing that it rendered the present revenue appeal infructuous. Consequently, the Tribunal dismissed the appeal. This decision highlights the tribunal’s acknowledgment of earlier judicial findings and emphasizes the finality of decisions once higher judicial bodies have spoken.
This ruling reinforces the procedural integrity of the tax appellate process, ensuring that once an assessment order is quashed by a competent authority, subsequent appeals based on the same grounds are considered redundant. The case is significant as it underscores the importance of final decisions by tribunals and the impacts of revisionary orders under tax law.
Order pronounced in the open court on May 2, 2023, confirming the dismissal of the appeal and underscoring the principle of respect for higher judicial authority in tax dispute resolutions.
Delhi Tribunal Dismissal of DCIT vs. Delhi Gurgaon Super Connectivity for AY 2014-15
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