JRW TRANSFREIGHT PRIVATE LTD. ,J J ROAD, UPPER BAZAR, RANCHI V. ASSISTANT DIRECTOR OF INCOME TAX, CPC, BENGALURU

ITA 211/RAN/2023

AI Insights

JRW Transfreight Pvt Ltd. appealed against the order of the CIT(A) for the assessment year 2020-2021. The core issue was the intimation issued under section 143(1) of the Income Tax Act by the Centralized Processing Center (CPC), which made adjustments without issuing a mandatory show cause notice to the assessee. Both the assessee's representative and the Senior Departmental Representative conceded that no such notice was issued. The tribunal, referencing the provisions of section 143(1), held that the lack of a show cause notice invalidated the intimation, leading to the allowance of the appeal.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 633319 (ITAT-RANCHI)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 13-06-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: DB
• Assessment Year: 2020-2021
• Laws Referred To: Income Tax Act
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: KHUBCHANDT PANDYA
• Assessee Lawyers: AJAYA PODDAR

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL, BEFORE AND RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER JRW Transfreight Pvt Ltd., J J Road, Upper Bazar, Ranchi PAN/GIR No.aaecj 2779 e (Appellant Per Bench This is an appeal filed by the assessee against the order of the ld CIT(A) NFAC Delhi dated assessment year 2020 2. Shri Khubchand T Pandya, ld Sr Ajaya Poddar, ld AR appeared for the assessee. IN THE INCOME TAX APPELLATE TRIBUNAL, RANCHI BENCH, RANCHI BEFORE S/SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER ITA No.211/RAN/2023 Assessment Year: 2020-2021 JRW Transfreight Pvt Ltd., J J Road, Upper Bazar, Ranchi Vs. ITO, Ward-1(1), Ranchi aaecj 2779 e (Appellant) .. ( Respondent Assessee by : Shri Ajaya Poddar, AR Revenue by :Shri Khubchand T Pandya, Sr DR Date of Hearing : 13/06/202 Date of Pronouncement :13/06/202 O R D E R This is an appeal filed by the assessee against the order of the ld CIT(A) dated2.8.2023 in Appeal No.NFAC/2019-20/10178037 2020-2021. Shri Khubchand T Pandya, ld Sr DR appeared for the revenue and Shri ld AR appeared for the assessee. P a g e 1 | 3 IN THE INCOME TAX APPELLATE TRIBUNAL, SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER 1(1), Ranchi Respondent) ri Ajaya Poddar, AR hri Khubchand T Pandya, Sr DR /2025 /2025 This is an appeal filed by the assessee against the order of the ld CIT(A)- 20/10178037 for the DR appeared for the revenue and Shri ITA No.211/Ran/2023 Assessment Year : 2020-21 P a g e 2 | 3 3. It was submitted by ld AR that this is an appeal against the order u/s.143(1) of the Act issued by the CPC. It was the submission that as per the provisions of section 143(1) of the Act, before making any adjustment, a show cause notice has to be issued to the assessee. It was the submission that no show cause notice has been issued to the assessee, therefore, the intimation issued u/s.143(1) is liable to be quashed. 4. In reply, ld Sr DR conceded that no show cause notice u/s.143(1) to the assessee. 5. We have considered the rival submission. A perusal of intimation u/s.143(1) of the Act also does not show of any show cause notice being issued to the assessee. A perusal of provisions of section 143(1) of the Act shows that it is compulsory for the revenue to issue show cause notice before making any adjustment in the intimation u/s.143(1) of the Act. This being so, as no show cause notice under the provisions of section 143(1) has been issued before making adjustment, the intimation issued u/s.143(1) stands quashed. 6. In the result, appeal of the assessee stands allowed. Order dictated and pronounced in the open court on 13/06/2025. Sd/- Sd/- (RATNESH NANDAN SAHAY) (GEORGE MATHAN) ACCOUNTANT MEMBER JUDICIAL MEMBER Ranchi; Dated 13/06/2025 B.K.Parida, SPS (OS) ITA No.211/Ran/2023 Assessment Year : 2020-21 P a g e 3 | 3 Copy of the Order forwarded to : By order Sr.Pvt.secretary ITAT, Ranchi 1. The Appellant : JRW Transfreight Pvt Ltd., J J Road, Upper Bazar, Ranchi 2. The Respondent: ITO, Ward-1(1), Ranchi 3. The CIT(A)-NFAC 4. Pr.CIT, Ranchi 5. DR, ITAT, 6. Guard file. //True Copy// "