AI Insights
The case involves Raghunandan Impex Pvt. Ltd., which appealed against the order of the Commissioner of Income-tax (Appeals) concerning a penalty under Section 271(1)(c) of the Income Tax Act for the assessment year 2012-2013. The penalty was related to non-genuine purchases of traded goods amounting to Rs. 25,00,000. The appellant argued that the penalty should not be decided until the quantum appeal was resolved, as the outcome of the quantum appeal would directly affect the penalty. The Tribunal noted that the appellant was unaware of the CIT(A)'s order due to it being sent to the email of a former Chartered Accountant, and only became aware upon departmental intimation regarding recovery proceedings. The Tribunal found the delay in filing the appeal to be justified and not intentional, leading to the setting aside of the CIT(A)'s order and restoration of the matter for decision post the quantum appeal.
Appeal Details
Counselvise Citation
[2025] 140 COUNSELVISE.COM (IT) 782895 (ITAT-SURAT)
Assessee PAN
Bench
Appeal Number
CRN Number
Duration Of Justice
4 month(s) 26 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
30-10-2025
Appeal Filed By
Assessee
Order Result
Partly Allowed
Bench Allotted
SMC
Assessment Year
2012-2013
Appeal Filed On
04-06-2025
Judgement Text
"IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH “SMC” SURAT BEFORE SHRI SANDEEP GOSAIN (JUDICIAL MEMBER) AND SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) ITA No. 641/SRT/2025 Assessment Year: 2012-2013 Raghunandan Impex Pvt. Ltd., 6/2037, Office No. 205, 2nd floor, Papadwala Building, Bhoja Bhai Ni Sheri, Mahidharpura, Surat-395003. Vs. ITO Ward 2(1)(1), Room No. 222, Aayakar Bhavan, Majura Gate, Surat-395001. PAN NO. AAECR 5688 Q Appellant Respondent Assessee by : Mr. Prakash Jhunjhunwala, CA Revenue by : Mr. J.K. Chandnani, Sr. DR Date of Hearing : 08/10/2025 Date of pronouncement : 30/10/2025 ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against order dated 27.11.2023 passed by the Ld. Commissioner of Income-tax (Appeals) – National Faceless Appeal Centre, Delhi [in short ‘the Ld. CIT(A)’] for assessment year 2012-2013, raising following grounds: 1.0 On facts and circumstances of the case and in law, Ld. CIT(A), before deciding the quantum appeal, erred in passing the appeal order pertaining to levy of Penalty u/s.271(1)(c) of the Act; 2.0 On facts and circumstances of the case and in law, Ld CIT(A) erred in deciding the penalty appeal, without issuing any Printed from counselvise.com notice of hearing, thereby justice; 3.0 On facts and circumstances of the case and in Law, Ld CIT(A) erred in not condoning the delay in filing of the appeal of 335 days, though there exist bonafide reasons that had precluded the appellant to file t 4.0 On facts and circumstances of the case and in Law, Ld. CIT(A) ought to have deleted the levy of penalty u/s.271(1X(c) of Rs.7,72,500/ non-genuine purchase of traded goods made from M/s. Gangotri Exim P Lid and M/s. Aditi Gems Pvt Ltd of Rs.25,00,000/ 5.0 The Ld. CIT(A) ought to have considered the bonafide explanation and existence of debatable issues and divergent views. under which circumstances the levy of penalty u/s.271(1)(c) is un 2. At the very outset, the our attention to the defective memo issued by the Registry pointing out a delay of appeal. The Ld. Counsel by circumstances wholly beyond the control of the assessee and supported his plea by placing on record an affidavit duly sworn by Shri Kailash B. Tiwadi company. 2.1 In the said affidavit, the deponent has deposed, that the impugned order of the (Appeals) was transmitted to the e belonging to the assessee’s erstwhile Chartered Accountant. The said Chartered Accountant had severed his professional association with the assessee without intimation; and that consequently, the assessee remained wholly unaware of the order’s passing. It was only upon receipt of a telephonic ITA No. 641/SRT/2025 Raghunandan Impex Pvt. Ltd notice of hearing, thereby violated the principle of natural 3.0 On facts and circumstances of the case and in Law, Ld CIT(A) erred in not condoning the delay in filing of the appeal of 335 days, though there exist bonafide reasons that had precluded the appellant to file the appeal in time: 4.0 On facts and circumstances of the case and in Law, Ld. CIT(A) ought to have deleted the levy of penalty u/s.271(1X(c) of Rs.7,72,500/- in respect of addition made u/s.68 of alleged genuine purchase of traded goods made from M/s. Exim P Lid and M/s. Aditi Gems Pvt Ltd of Rs.25,00,000/-; 5.0 The Ld. CIT(A) ought to have considered the bonafide explanation and existence of debatable issues and divergent views. under which circumstances the levy of penalty u/s.271(1)(c) is unjustified. At the very outset, the Ld. Counsel for the assessee our attention to the defective memo issued by the Registry pointing out a delay of 490 days in the filing of the present Ld. Counsel submitted that the delay was occasio by circumstances wholly beyond the control of the assessee and supported his plea by placing on record an affidavit duly sworn Shri Kailash B. Tiwadi, Managing Director of the assessee In the said affidavit, the deponent has deposed, that the impugned order of the Ld. Commissioner of Income was transmitted to the e-mail address d0829@msco.in belonging to the assessee’s erstwhile Chartered Accountant. The said Chartered Accountant had severed his professional association with the assessee without intimation; and that consequently, the assessee remained wholly unaware of the order’s passing. It was only upon receipt of a telephonic ITA No. 641/SRT/2025 2 Raghunandan Impex Pvt. Ltd violated the principle of natural 3.0 On facts and circumstances of the case and in Law, Ld CIT(A) erred in not condoning the delay in filing of the appeal of 335 days, though there exist bonafide reasons that had 4.0 On facts and circumstances of the case and in Law, Ld. CIT(A) ought to have deleted the levy of penalty u/s.271(1X(c) of in respect of addition made u/s.68 of alleged genuine purchase of traded goods made from M/s. Exim P Lid and M/s. Aditi Gems Pvt Ltd of 5.0 The Ld. CIT(A) ought to have considered the bonafide explanation and existence of debatable issues and divergent views. under which circumstances the levy of penalty Ld. Counsel for the assessee invited our attention to the defective memo issued by the Registry in the filing of the present submitted that the delay was occasioned by circumstances wholly beyond the control of the assessee and supported his plea by placing on record an affidavit duly sworn , Managing Director of the assessee In the said affidavit, the deponent has deposed, inter-alia, Ld. Commissioner of Income-tax d0829@msco.in, belonging to the assessee’s erstwhile Chartered Accountant. The said Chartered Accountant had severed his professional association with the assessee without intimation; and that consequently, the assessee remained wholly unaware of the order’s passing. It was only upon receipt of a telephonic Printed from counselvise.com intimation from the Department in connection with recovery proceedings that the order. 2.2 Thereafter, the assessee immediately engaged new counsel and caused the present appeal to be filed. It was further explained that the assessee had been under a bona fide belief that the appeal relating to to the conclusion of the quantum appeal pending before the CIT(A), and that such misapprehension, coupled with personal and familial exigencies, contributed to the delay. 2.3 It was also brought to our notice that Managing Director passed away on place in Bhilwara, Rajasthan considerable period attending to her illness and subsequent family disputes; and that he eventually relocated to the closure of business operations, thereby compounding his difficulty in ensuring timely compliance. The relevant portions of the affidavit, containing the sequence of events and the explanation for delay, are extracted in the record for ready reference.The relevant part of the affidavit is reproduced as under: 3. THAT, the delay in filing of the 2nd appeal before Hon'ble ITAT had occurred under the bonafide reasons and compelling circumstances beyond my control, stated as under : a) The CIT(A) order had not been served to me, since was sent at the email address viz. d0829@msco.in belonging to my earlier Chartered Accountant M/s Manoj Sandhya & Co. However, the said Chartered Accountant deserted me and did ITA No. 641/SRT/2025 Raghunandan Impex Pvt. Ltd intimation from the Department in connection with recovery proceedings that the assessee became aware of the appellate Thereafter, the assessee immediately engaged new counsel and caused the present appeal to be filed. It was further explained that the assessee had been under a bona fide belief that the appeal relating to penalty could not be disposed of prior to the conclusion of the quantum appeal pending before the , and that such misapprehension, coupled with personal and familial exigencies, contributed to the delay. It was also brought to our notice that the mother of the Managing Director passed away on 01.02.2024 at his native Bhilwara, Rajasthan; that he remained there for a considerable period attending to her illness and subsequent family disputes; and that he eventually relocated to the closure of business operations, thereby compounding his difficulty in ensuring timely compliance. The relevant portions of the affidavit, containing the sequence of events and the explanation for delay, are extracted in the record for ready The relevant part of the affidavit is reproduced as 3. THAT, the delay in filing of the 2nd appeal before Hon'ble ITAT had occurred under the bonafide reasons and compelling circumstances beyond my control, stated as under :- a) The CIT(A) order had not been served to me, since was sent at the email address viz. d0829@msco.in belonging to my earlier Chartered Accountant M/s Manoj Sandhya & Co. However, the said Chartered Accountant deserted me and did ITA No. 641/SRT/2025 3 Raghunandan Impex Pvt. Ltd intimation from the Department in connection with recovery assessee became aware of the appellate Thereafter, the assessee immediately engaged new counsel and caused the present appeal to be filed. It was further explained that the assessee had been under a bona fide belief penalty could not be disposed of prior to the conclusion of the quantum appeal pending before the Ld. , and that such misapprehension, coupled with personal the mother of the at his native ; that he remained there for a considerable period attending to her illness and subsequent family disputes; and that he eventually relocated to Mumbai after the closure of business operations, thereby compounding his difficulty in ensuring timely compliance. The relevant portions of the affidavit, containing the sequence of events and the explanation for delay, are extracted in the record for ready The relevant part of the affidavit is reproduced as 3. THAT, the delay in filing of the 2nd appeal before Hon'ble ITAT had occurred under the bonafide reasons and compelling a) The CIT(A) order had not been served to me, since was sent at the email address viz. d0829@msco.in belonging to my earlier Chartered Accountant M/s Manoj Sandhya & Co. However, the said Chartered Accountant deserted me and did Printed from counselvise.com not inform me about the pa upon receipt of a telephone call from the Income Tax department, I was made aware that the 1 ^ (st) appeal pertaining to levy of penalty has been passed. Accordingly, I immediately appointed M/s. Prakash Jhunjhunwala & LLP, Chartered Accountant and filed the 2 ^ (nd) appeal with a prayer for condonation of delay; b) I and my Chartered Accountant were under a bonafide belief that the penalty appeal cannot be decided before the decision on quantum appeal. I had alread submissions in the quantum appeal and was under a belief that on following the provision of Sec.274(2), the penalty u/s.271(1)(c) shall automatically stand modified upon deletion/ reduction of the quantum addition. Accordingly, till the decision of Ld. CIT(A) of quantum addition, the 2nd appeal pertaining to levy of penalty u/s.271(1)(c) could not be filed; c) I had gone to my hometown situated at Bhilwara, Rajasthan for substantial period of time to attend the serious medical illness of my moth (copy of death certificate enclosed). Thereafter, due to bitterness and disputes with my elder brother on ancestral property matters, I was residing at Bijaynagar, Rajasthan and my non-presence at Surat had caused t 2nd appeal before Hon'ble ITAT; d) Due to complete closure of my business activities, I had permanently shifted my place of residence at Mumbai. Also, I am not conversant with the Income Tax Law and I did not have any staffs to as confusion in respect of the quantum and penalty appeals had resulted in delay in filing of the 2nd appeal before Hon'ble ITAT; There is no willful attempt nor gross negligence to delay the filing of the 2nd appeal, howeve unintentionally under the bonafide reasons stated hereinabove. I respectfully make a prayer before the Hon'ble Income Tax Appellate Tribunal to adopt a liberal approach and condone the delay in filing of the 2nd appeal and decide t appeal on merits; 3. We have carefully heard the rival submissions and have perused the entire record with circumspection. Although there is indeed a considerable delay in the institution of the appeal, the explanation tendered by the assessee is neith evasive. The reasons adduced, duly supported by affidavit, reveal ITA No. 641/SRT/2025 Raghunandan Impex Pvt. Ltd not inform me about the passing of the CIT(A) order. It is only upon receipt of a telephone call from the Income Tax department, I was made aware that the 1 ^ (st) appeal pertaining to levy of penalty has been passed. Accordingly, I immediately appointed M/s. Prakash Jhunjhunwala & LLP, Chartered Accountant and filed the 2 ^ (nd) appeal with a prayer for condonation of delay; b) I and my Chartered Accountant were under a bonafide belief that the penalty appeal cannot be decided before the decision on quantum appeal. I had already made part submissions in the quantum appeal and was under a belief that on following the provision of Sec.274(2), the penalty u/s.271(1)(c) shall automatically stand modified upon deletion/ reduction of the quantum addition. Accordingly, till n of Ld. CIT(A) of quantum addition, the 2nd appeal pertaining to levy of penalty u/s.271(1)(c) could not be filed; c) I had gone to my hometown situated at Bhilwara, Rajasthan for substantial period of time to attend the serious medical illness of my mother and she ultimately died on 01/02/2024 (copy of death certificate enclosed). Thereafter, due to bitterness and disputes with my elder brother on ancestral property matters, I was residing at Bijaynagar, Rajasthan and presence at Surat had caused the delay in filing of the 2nd appeal before Hon'ble ITAT; d) Due to complete closure of my business activities, I had permanently shifted my place of residence at Mumbai. Also, I am not conversant with the Income Tax Law and I did not have any staffs to assist me to file the appeals and my confusion in respect of the quantum and penalty appeals had resulted in delay in filing of the 2nd appeal before Hon'ble There is no willful attempt nor gross negligence to delay the filing of the 2nd appeal, however the delay had occurred unintentionally under the bonafide reasons stated hereinabove. I respectfully make a prayer before the Hon'ble Income Tax Appellate Tribunal to adopt a liberal approach and condone the delay in filing of the 2nd appeal and decide t appeal on merits;” We have carefully heard the rival submissions and have perused the entire record with circumspection. Although there is indeed a considerable delay in the institution of the appeal, the explanation tendered by the assessee is neither perfunctory nor evasive. The reasons adduced, duly supported by affidavit, reveal ITA No. 641/SRT/2025 4 Raghunandan Impex Pvt. Ltd ssing of the CIT(A) order. It is only upon receipt of a telephone call from the Income Tax department, I was made aware that the 1 ^ (st) appeal pertaining to levy of penalty has been passed. Accordingly, I immediately appointed M/s. Prakash Jhunjhunwala & Co. LLP, Chartered Accountant and filed the 2 ^ (nd) appeal with a b) I and my Chartered Accountant were under a bonafide belief that the penalty appeal cannot be decided before the y made part submissions in the quantum appeal and was under a belief that on following the provision of Sec.274(2), the penalty u/s.271(1)(c) shall automatically stand modified upon deletion/ reduction of the quantum addition. Accordingly, till n of Ld. CIT(A) of quantum addition, the 2nd appeal pertaining to levy of penalty u/s.271(1)(c) could not be filed; c) I had gone to my hometown situated at Bhilwara, Rajasthan for substantial period of time to attend the serious medical er and she ultimately died on 01/02/2024 (copy of death certificate enclosed). Thereafter, due to bitterness and disputes with my elder brother on ancestral property matters, I was residing at Bijaynagar, Rajasthan and he delay in filing of the d) Due to complete closure of my business activities, I had permanently shifted my place of residence at Mumbai. Also, I am not conversant with the Income Tax Law and I did not sist me to file the appeals and my confusion in respect of the quantum and penalty appeals had resulted in delay in filing of the 2nd appeal before Hon'ble There is no willful attempt nor gross negligence to delay the r the delay had occurred unintentionally under the bonafide reasons stated hereinabove. I respectfully make a prayer before the Hon'ble Income Tax Appellate Tribunal to adopt a liberal approach and condone the delay in filing of the 2nd appeal and decide the We have carefully heard the rival submissions and have perused the entire record with circumspection. Although there is indeed a considerable delay in the institution of the appeal, the er perfunctory nor evasive. The reasons adduced, duly supported by affidavit, reveal Printed from counselvise.com that the delay was occasioned by a chain of bona fide and unavoidable circumstances the appellate order due to the conduct of the erstwhil Accountant, subsequent discovery of the order upon departmental intimation, personal bereavement, and a genuine misconception regarding the interlinkage between quantum and penalty proceedings. 3.1 We find substance in the plea that the assesse prevented by sufficient cause the Limitation Act, 1963, from filing the appeal within the prescribed time. 3.2 It is a well-enshrined principle of law, as laid down by the Hon’ble Supreme Court & Others [(1987) 167 ITR 471 (SC)], that the expression “sufficient cause” should receive a liberal and justice construction so as to advance the cause of substantial justice. The Court therein observed that technicalities permitted to defeat the ends of justice and that a litigant should not suffer for the inadvertence or default of his representative, particularly when the explanation is bona fide and devoid of malafides. 3.3 Adopting the same benevolent and are satisfied that the delay in the instant case is neither deliberate nor motivated by negligence but arose under circumstances beyond the reasonable control of the assessee. We ITA No. 641/SRT/2025 Raghunandan Impex Pvt. Ltd that the delay was occasioned by a chain of bona fide and unavoidable circumstances — including non-communication of the appellate order due to the conduct of the erstwhil Accountant, subsequent discovery of the order upon departmental intimation, personal bereavement, and a genuine misconception regarding the interlinkage between quantum and We find substance in the plea that the assesse sufficient cause within the meaning of Section 5 of the Limitation Act, 1963, from filing the appeal within the enshrined principle of law, as laid down by the Hon’ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji [(1987) 167 ITR 471 (SC)], that the expression “sufficient cause” should receive a liberal and justice construction so as to advance the cause of substantial justice. The Court therein observed that technicalities should not be permitted to defeat the ends of justice and that a litigant should not suffer for the inadvertence or default of his representative, particularly when the explanation is bona fide and devoid of Adopting the same benevolent and equitable approach, we are satisfied that the delay in the instant case is neither deliberate nor motivated by negligence but arose under circumstances beyond the reasonable control of the assessee. We ITA No. 641/SRT/2025 5 Raghunandan Impex Pvt. Ltd that the delay was occasioned by a chain of bona fide and communication of the appellate order due to the conduct of the erstwhile Chartered Accountant, subsequent discovery of the order upon departmental intimation, personal bereavement, and a genuine misconception regarding the interlinkage between quantum and We find substance in the plea that the assessee was within the meaning of Section 5 of the Limitation Act, 1963, from filing the appeal within the enshrined principle of law, as laid down by the quisition v. Mst. Katiji [(1987) 167 ITR 471 (SC)], that the expression “sufficient cause” should receive a liberal and justice-oriented construction so as to advance the cause of substantial justice. should not be permitted to defeat the ends of justice and that a litigant should not suffer for the inadvertence or default of his representative, particularly when the explanation is bona fide and devoid of equitable approach, we are satisfied that the delay in the instant case is neither deliberate nor motivated by negligence but arose under circumstances beyond the reasonable control of the assessee. We Printed from counselvise.com therefore, in the exercise of our judicial discretion delay of 490 days in the filing of the appeal. 4. Proceeding to the next issue, the assessee submitted that the appeal against the quantum assessment order is still pending adjudication before the CIT(A) and, therefore Ld. CIT(A) prior to the final determination of the quantum addition was premature. It was argued that the penalty imposed under Section 271(1)(c) is intrinsically dependent upon the fate of the corresponding quan modification, or sustenance of the same would directly influence the outcome of the penalty proceedings. 4.1 The Ld. Departmental Representative (DR) complete agreement, did not seriously controvert the fa matrix or the legal implications advanced by the 4.2 We have considered to the submissions of both sides. In principle, there is no statutory bar precluding the adjudicating a penalty appeal even while the quantum appeal remains pending. Nevertheless, in the judicial balance between technical authority and procedural fairness, it is always desirable that the determination of penalty nature—should await the final outcome of the quantum proceedings. ITA No. 641/SRT/2025 Raghunandan Impex Pvt. Ltd therefore, in the exercise of our judicial discretion, of 490 days in the filing of the appeal. Proceeding to the next issue, the Ld. Counsel for the submitted that the appeal against the quantum assessment order is still pending adjudication before the and, therefore, the disposal of the penalty appeal by the prior to the final determination of the quantum addition was premature. It was argued that the penalty imposed under Section 271(1)(c) is intrinsically dependent upon the fate of the corresponding quantum addition and that the deletion, modification, or sustenance of the same would directly influence the outcome of the penalty proceedings. Ld. Departmental Representative (DR), though not in complete agreement, did not seriously controvert the fa matrix or the legal implications advanced by the Ld. Counsel We have considered to the submissions of both sides. In principle, there is no statutory bar precluding the Ld. CIT(A) adjudicating a penalty appeal even while the quantum appeal remains pending. Nevertheless, in the judicial balance between technical authority and procedural fairness, it is always desirable that the determination of penalty—being consequential in should await the final outcome of the quantum ITA No. 641/SRT/2025 6 Raghunandan Impex Pvt. Ltd , condone the Ld. Counsel for the submitted that the appeal against the quantum assessment order is still pending adjudication before the Ld. , the disposal of the penalty appeal by the prior to the final determination of the quantum addition was premature. It was argued that the penalty imposed under Section 271(1)(c) is intrinsically dependent upon the fate of tum addition and that the deletion, modification, or sustenance of the same would directly influence , though not in complete agreement, did not seriously controvert the factual Ld. Counsel. We have considered to the submissions of both sides. In Ld. CIT(A) from adjudicating a penalty appeal even while the quantum appeal remains pending. Nevertheless, in the judicial balance between technical authority and procedural fairness, it is always desirable being consequential in should await the final outcome of the quantum Printed from counselvise.com 4.3 The rationale is self lies in the quantum addition; if that foundation is unsettled, the superstructure of penalty cannot stand independently. Should the quantum addition be deleted or modified, the penalty would automatically require proportionate reconsideration. Thus, in the larger interest of justice, avoidance of multiplicity, and consistency of adjudication, we deem it just, proper, and in consonance with judicial prudence that the penalty appeal be restored for decision after the disposal of the quantum appeal by the Ld. CIT(A). 5. Accordingly, we set aside the impugned order of the and restore the matter to his file with a direction that the penalty appeal be decided subsequent to outcome of the quantum assessment proceedings. 6. The Ld. CIT(A) shall, while doing so, first consider the issue of condonation of delay before him, if any, in accordance with law and upon affording due opportunity of hearing to the assessee, thereafter decide the issue of merit or any other ground challenging validity of penalty. 7. The ground No. 1 of the appeal of the assessee is accordingly allowed and the remaining grounds are rendered academic and therefore, same are not adjudicated upon at this stage. ITA No. 641/SRT/2025 Raghunandan Impex Pvt. Ltd The rationale is self-evident: the foundation of the penalty lies in the quantum addition; if that foundation is unsettled, the superstructure of penalty cannot stand independently. Should the quantum addition be deleted or modified, the penalty would matically require proportionate reconsideration. Thus, in the larger interest of justice, avoidance of multiplicity, and consistency of adjudication, we deem it just, proper, and in consonance with judicial prudence that the penalty appeal be decision after the disposal of the quantum appeal by Accordingly, we set aside the impugned order of the and restore the matter to his file with a direction that the penalty subsequent to and in conformity wi outcome of the quantum assessment proceedings. shall, while doing so, first consider the issue of condonation of delay before him, if any, in accordance with law and upon affording due opportunity of hearing to the assessee, thereafter decide the issue of merit or any other ground of penalty. The ground No. 1 of the appeal of the assessee is accordingly allowed and the remaining grounds are rendered academic and therefore, same are not adjudicated upon at this ITA No. 641/SRT/2025 7 Raghunandan Impex Pvt. Ltd evident: the foundation of the penalty lies in the quantum addition; if that foundation is unsettled, the superstructure of penalty cannot stand independently. Should the quantum addition be deleted or modified, the penalty would matically require proportionate reconsideration. Thus, in the larger interest of justice, avoidance of multiplicity, and consistency of adjudication, we deem it just, proper, and in consonance with judicial prudence that the penalty appeal be decision after the disposal of the quantum appeal by Accordingly, we set aside the impugned order of the Ld. CIT(A) and restore the matter to his file with a direction that the penalty in conformity with the shall, while doing so, first consider the issue of condonation of delay before him, if any, in accordance with law and upon affording due opportunity of hearing to the assessee, thereafter decide the issue of merit or any other ground The ground No. 1 of the appeal of the assessee is accordingly allowed and the remaining grounds are rendered academic and therefore, same are not adjudicated upon at this Printed from counselvise.com 8. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced by way display o board on 30/10/2025 under Rule 34(4) of ITAT Rules, 1963. Sd/- (SANDEEP GOSAIN JUDICIAL MEMBER Surat; Dated: 30/10/2025 Rahul Sharma, Sr. P.S. (on Tour) Copy of the Order forwarded to 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Surat 5. Guard file. //True Copy// ITA No. 641/SRT/2025 Raghunandan Impex Pvt. Ltd In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced by way display of result on notice /10/2025 under Rule 34(4) of ITAT Rules, 1963. Sd/ (SANDEEP GOSAIN) (OM PRAKASH KANT JUDICIAL MEMBER ACCOUNTANT MEMBER Copy of the Order forwarded to : BY ORDER, (Assistant Registrar) ITAT, Surat ITA No. 641/SRT/2025 8 Raghunandan Impex Pvt. Ltd In the result, the appeal of the assessee is allowed for f result on notice /10/2025 under Rule 34(4) of ITAT Rules, 1963. Sd/- OM PRAKASH KANT) ACCOUNTANT MEMBER BY ORDER, (Assistant Registrar) ITAT, Surat Printed from counselvise.com "
Other Referred Cases
Collector, Land Acquisition v. Mst. Katiji [(1987) 167 ITR 471 (SC)]
Laws Referred To
Income Tax Act
1:1 Consultation on SME Listing
₹0
1:1 Consultation on Startup Fundraising
₹5000
1:1 Consultation on Tax Litigation
₹1
Shipping and Logistics Agreement
₹0
Research Collaboration Agreement
₹0
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