CRISIL LIMITED ,MUMBAI V. DCIT, CIRCLE 15(1)(2), MUMBAI

ITA 6600/MUM/2025

AI Insights

Crisil Limited appealed against the order of the Learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre, which had dismissed their earlier appeal. The primary contention was that the assessee was not provided a fair opportunity to be heard before the Ld.CIT(A) made a decision. The Tribunal noted that the assessee had sought adjournments to compile necessary submissions, but the Ld.CIT(A) proceeded to pass an order without further adjournment. Both parties agreed that the matter should be set aside to the Ld.CIT(A) for a fresh decision.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 792091 (ITAT-MUMBAI)
• Duration Of Justice: 1 month(s) 26 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 12-12-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: I
• Assessment Year: 2022-2023
• Appeal Filed On: 16-10-2025
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: SATYAPAL KUMAR
• Assessee Lawyers: DHANESH BAFNAAMOL MAHAJAN
• Keywords: Set aside; Opportunity of being heard
• Section: 143(3)

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “I” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA No. 6600/Mum/2025 Assessment Year : 2022-23 Crisil Limited, Lightbridge IT Park, Crisil Limited, Saki Vihar Road, Andheri East, Mumbai-400072. PAN : AAACT3151E vs. Deputy Commissioner of Income Tax, Circle-15(1)(2), Aayakar Bhavan, M.K.Road, Mumbai-400020. (Appellant) (Respondent) For Assessee : Shri Dhanesh Bafna/Amol Mahajan For Revenue : Shri Satya Pal Kumar, CIT-DR Date of Hearing : 09-12-2025 Date of Pronouncement : 12-12-2025 O R D E R PER VIKRAM SINGH YADAV, A.M : This is an appeal filed by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi [„Ld.CIT(A)‟], dated 14-08-2025, pertaining to Assessment Year (AY) 2022-23. 2. Briefly stated, facts of the case are that assessment in this case was completed u/s. 143(3) r.w.s. 144B of the Income Tax Act, 1961 („the Act‟), vide order dt. 27-02-2025. The assessee thereafter carried the matter in Printed from counselvise.com 2 ITA No. 6600/Mum/2025 appeal before the Ld.CIT(A), who has since dismissed the appeal and against the said order, the assessee is in appeal before us. 3. The limited submission raised by the Ld.AR on behalf of the assessee was that the Ld.CIT(A) has passed the impugned order, without providing a fair opportunity of being heard to the assessee and it was accordingly submitted that the matter may be set aside to the file of the Ld.CIT(A) and the assessee may be allowed one more opportunity. In this regard, our reference was drawn to the impugned order, wherein there is reference to notices issued by the Ld.CIT(A) and in respect of which the assessee has sought adjournment for the reason that it is in the process of compiling the necessary submissions and thereafter, the matter was listed for hearing on 14-08-2025 and there again, the assessee has sought certain further time and it was submitted that without adjourning the matter any further, the Ld.CIT(A) has passed the impugned order on 14-08-2025 itself. It was accordingly submitted that the assessee deserves one more opportunity to put forward its submissions and file necessary documentation in support of various grounds of appeal and the matter may be accordingly set aside to the file of the Ld. CIT(A). 4. The Ld. DR has been heard, who has not raised any specific objection, where the matter is set aside to the file of the Ld.CIT(A). 5. Considering the limited prayer raised by the Ld.AR on behalf of the assessee which has not been contested by the Ld.DR, the matter is set- aside to the file of Ld.CIT(A) for deciding the same afresh as per law, after providing reasonable opportunity to the assessee. Printed from counselvise.com 3 ITA No. 6600/Mum/2025 6. Needless to say, the assessee shall attend to the proceedings and file necessary submissions/documentation as so advised and shall co-operate with the Ld.CIT(A) for expeditious disposal of the matter under appeal. 7. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced in the open court on 12-12-2025 Sd/- Sd/- [SANDEEP SINGH KARHAIL] [VIKRAM SINGH YADAV] JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai, Dated: 12-12-2025 TNMM Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file By Order Dy./Asst. Registrar I.T.A.T, Mumbai Printed from counselvise.com "