ALLIED TRANSLINK PRIVATE LIMITED,YASHWANT NAGAR, PIMPRI V. ACIT/DCIT, CENTRAL CIRCLE

ITA 3219/PUN/2025

AI Insights

The case involves Allied Translink Private Limited, which did not file a regular return of income for the Assessment Year 2017-18. Following a notice under section 148 of the Income-tax Act, 1961, the Assessing Officer made a best judgment assessment, adding Rs. 18,30,420 to the assessee's income due to non-compliance. The assessee's appeal to the CIT(A) was dismissed for non-compliance with procedural requirements. The Tribunal, considering the circumstances and the request of the assessee's counsel, decided to set aside the CIT(A)'s decision and remand the case for a fresh hearing on merits.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 846657 (ITAT-PUNE)
• Duration Of Justice: 3 month(s) 1 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-03-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: Pune
• Assessment Year: 2017-2018
• Appeal Filed On: 26-12-2025
• Laws Referred To: Income-tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: DAYNAND JAWALIKAR
• Assessee Lawyers: SHARWAN KR. JHA
• Keywords: Set aside; Reasonable cause

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “SMC”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER आयकर अपील सं. / ITA No.3219/PUN/2025 Assessment Year : 2017-18 Allied Translink Private Limited Flat No.02, Bhakti Chambers Yashwant Nagar, Pimpri, Pune-411018 Maharashtra PAN : AAOCA2300A Vs. Assistant Commissioner of Income Tax, Central Circle 2(1), Pune Appellant Respondent आदेश / ORDER The captioned appeal at the instance of assessee pertaining to the Assessment Year 2017-18 is directed against the order dated 01.12.2025 of Commissioner of Income Tax (Appeals), Pune-12 passed u/s.250 of the Income-tax Act, 1961 (hereinafter also called ‘the Act’) arising out of the Assessment Order dated 29.03.2022 passed u/s.144 of the Act. 2. At the outset, ld. Counsel for the assessee submitted that due to bonafide reasons assesse could not make proper compliance before ld.CIT(A) resulting into dismissal of appeal. He submitted that if an opportunity is granted then assesse can make necessary submissions and furnish details before Assessee by : Shri Sharwan Kr. Jha (Through Virtual) Revenue by : Shri Daynand Jawalikar- Addl.CIT (Through Virtual) Date of hearing : 10.03.2026 Date of pronouncement : 27.03.2026 Printed from counselvise.com ITA No.3219/PUN/2025 Allied Translink Pvt. Ltd. 2 Ld.CIT(A) in support of its grounds of appeals. Ld. DR did not object to the request made by ld. Counsel for the assessee. 3. I have heard the rival contentions and perused the record placed before me. I note that the assessee is a private limited company and did not filed regular return of income for AY 2017- 18. After issuance of valid notice u/s.148 of the Act, Ld.Assessing officer passed the best judgement as the assesse did not made proper compliance. Ld.AO made addition of Rs.18,30,420/- against which assessee preferred appeal before Ld.CIT(A) but again failed to respond to various notices issued by Ld.CIT(A). Before me Ld.Counsel for the assesse has prayed for affording one of more opportunity to plead before Ld.CIT(A). 4. I find that ld.CIT(A) has not decided the issues raised in the instant appeal on merits, therefore considering the prayer made by ld. Counsel for the assessee and in the larger interest of justice, I deem it proper to restore the issues on merits back to the file ld. CIT(A) for denovo adjudication. In view thereof, without dwelling into merits of the issue, the issues raised in the instant appeal are being remitted to the file of ld.CIT(A). Needless to mention that ld.CIT(A) in the set aside proceedings shall provide reasonable opportunity of hearing to the assessee and consider the documents/evidences to be filed by the assessee and pass a speaking order as contemplated u/s.250(6) of the Act. Assessee is directed to update email and contact details on the ITBA portal. Assessee is also directed to remain vigilant and not to take adjournment unless otherwise required for reasonable cause, failing which the ld.CIT(A) shall be free to proceed in accordance with law. Finding of the Ld.CIT(A) is set aside and Printed from counselvise.com ITA No.3219/PUN/2025 Allied Translink Pvt. Ltd. 3 Grounds of appeal raised by the assessee are allowed for statistical purposes. 5. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced on this 27th day of March, 2026. Sd/- (MANISH BORAD) ACCOUNTANT MEMBER पुणे / Pune; दिन ंक / Dated : 27th March, 2026. Satish आदेश की प्रतिलिपि अग्रेपिि / Copy of the Order forwarded to : 1. अपील र्थी / The Appellant. 2. प्रत्यर्थी / The Respondent. 3. The Pr. CIT concerned. 4. विभ गीय प्रतितनधि, आयकर अपीलीय अधिकरण, “SMC” बेंच, पुणे / DR, ITAT, “SMC” Bench, Pune. 5. ग र्ड फ़ इल / Guard File. आिेश नुस र / BY ORDER, // True Copy // Assistant Registrar आयकर अपीलीय अधिकरण, पुणे / ITAT, Pune Printed from counselvise.com "