RATHINAMPILLAI NAGARAJAN,TRICHY V. INCOME TAX OFFICER, WARD 2(1), TRICHY, CANTONMENT TRICHY

ITA 4085/CHNY/2025

AI Insights

The case involves an appeal by Shri Rathinampillai Nagarajan against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, which was passed under section 250 of the Income Tax Act, 1961 for the Assessment Year 2020-21. The primary issue in the appeal was the classification of the assessee's agricultural income, which was initially added as 'income from other sources' by the Assessing Officer due to insufficient evidence provided by the assessee. The FAA's decision was ex-parte as the assessee failed to respond to multiple notices. The assessee, represented by Shri M.K. Rangaswamy, CA, argued that due to his unfamiliarity with online proceedings, he could not respond adequately, leading to the dismissal of his appeal by the FAA. The Departmental Representative, Ms. V. Aswathy, JCIT, contended that the assessee was given adequate opportunities, and thus the appeal should be dismissed.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 837529 (ITAT-CHENNAI)
• Duration Of Justice: 1 month(s) 22 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 20-02-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: D
• Assessment Year: 2020-2021
• Appeal Filed On: 29-12-2025
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: V. ASWATHY
• Assessee Lawyers: M.K.RANGASWAMY
• Keywords: Principle of natural justice

Judgement Text

"आयकर अपीलȣय अͬधकरण, ‘डी’ Ûयायपीठ, चेÛनई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI Įी जॉज[ जॉज[ क े, उपाÚय¢ एवं Įी इंटूरȣ रामा राव, लेखा सदèय क े सम¢ BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENT AND SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.: 4085/CHNY/2025 िनधाᭅरण वषᭅ/Assessment Year: 2020-21 Shri Rathinampillai Nagarajan, No.72, Ashok Nagar, R.M.S. Colony, Karumandapam, Trichy – 620 001. PAN: CEYPN 6032D Vs. The Income Tax Officer, Ward 2(1), Trichy. (अपीलाथᱮ/Appellant) (ᮧ᭜यथᱮ/Respondent) अपीलाथᱮ कᳱ ओर से/Appellant by : Shri M.K. Rangaswamy, CA ᮧ᭜यथᱮ कᳱ ओर से/Respondent by : Ms. V. Aswathy, JCIT सुनवाई कᳱ तारीख/Date of Hearing : 18.02.2026 घोषणा कᳱ तारीख/Date of Pronouncement : 20.02.2026 आदेश/ O R D E R PER GEORGE GEORGE K, VICE PRESIDENT: This appeal filed by the assessee is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, dated 25.07.2025 passed under section 250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2020-21. Printed from counselvise.com ITA No.4085/Chny/2025 :- 2 -: 2. At the very outset, we notice that the order passed by the First Appellate Authority (FAA) is ex-parte, since there was no compliance from the assessee to three notices issued from the office of the First Appellate Authority. 3. The Ld.AR submitted that the assessee is an agriculturist. The assessee claimed gross agricultural income of Rs.39,62,750/- after incurring expenditure of Rs.5,98,050/- and had disclosed net agricultural income of Rs.33,64,700/-. During the course of assessment proceedings, assessee was directed to explain the receipt of agricultural income. In response to show-cause notice issued, assessee had submitted partial details / evidence in support of holding agricultural land, etc. However, no details were furnished with regard to earning of agricultural income to the extent of gross agricultural income of Rs.39,62,750/-. Hence, the AO added the entire agricultural income as ‘income from other sources’. The Ld.AR further submitted that since the assessee has not responded to the show-cause notices issued from the office of FAA, the FAA dismissed the appeal of the assessee. The Ld.AR submitted that the assessee is a farmer and is not well-versed with online proceedings, hence Printed from counselvise.com ITA No.4085/Chny/2025 :- 3 -: the assessee failed to respond to the notices issued from the office of the FAA. Therefore, it was prayed that one last opportunity may be provided to the assessee to represent his case before the FAA. 4. The Ld.DR submitted that adequate opportunities were provided from the offices of the FAA and there is no violation of principles of natural justice. Therefore, it was prayed the appeal of the assessee may be dismissed. 5. We have heard rival submissions and perused the materials on record. The proceedings before the FAA was ex-parte, since the assessee did not respond to various notices issued from the office of the FAA. The Ld.AR submitted that assessee being an agriculturist not well-versed with online proceedings failed to respond to the notices issued from the FAA. We strongly deprecate the nonchalant attitude of the assessee in not responding to the notices issued from the offices of the FAA. However, in the interest of justice and fair play, we are of the view that the matter ought to be restored to the files of the FAA as a last opportunity. Accordingly, the matter is remitted to the files of the FAA for fresh adjudication. The FAA shall afford reasonable opportunity of hearing to the assessee. The assessee is directed to Printed from counselvise.com ITA No.4085/Chny/2025 :- 4 -: co-operate with the Revenue and shall not seek unnecessary adjournment. It is ordered accordingly. 6. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced in the open court on 20th February, 2026 at Chennai. Sd/- Sd/- (इंटूरȣ रामा राव) (INTURI RAMA RAO) लेखा सदèय/ACCOUNTANT MEMBER (जॉज[ जॉज[ क े) (GEORGE GEORGE K) उपाÚय¢ /VICE PRESIDENT चे᳖ई/Chennai, ᳰदनांक/Dated, the 20th February, 2026 RSR आदेश कȧ ĤǓतͧलͪप अĒेͪषत/Copy to: 1. अपीलाथȸ/Appellant 2. Ĥ×यथȸ/Respondent 3. आयकर आयुÈत /CIT, Madurai 4. ͪवभागीय ĤǓतǓनͬध/DR 5. गाड[ फाईल/GF. Printed from counselvise.com "