https://www.taxtmi.com/caselaws?id=762110 ITAT Hyderabad ruled that an assessee can raise issues before the Tribunal through Rule 27 application even when CIT(A) failed to adjudicate those issues. The case involved penalty proceedings under sections 270A and 271AAB where the assessee challenged vague show cause notices. Following precedents from Madras HC and Bombay HC, ITAT held that unadjudicated issues by CIT(A) are deemed decided against the assessee, allowing them to be raised before the Tribunal without separate appeal. The matter was remanded to CIT(A) for proper consideration of the preliminary legal issue regarding validity of penalty proceedings. en-us Thu, 14 Nov 2024 00:00:00 +0530 Sun, 24 Nov 2024 09:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762110 ITAT Hyderabad ruled that an assessee can raise issues before the Tribunal through Rule 27 application even when CIT(A) failed to adjudicate those issues. The case involved penalty proceedings under sections 270A and 271AAB where the assessee challenged vague show cause notices. Following precedents from Madras HC and Bombay HC, ITAT held that unadjudicated issues by CIT(A) are deemed decided against the assessee, allowing them to be raised before the Tribunal without separate appeal. The matter was remanded to CIT(A) for proper consideration of the preliminary legal issue regarding validity of penalty proceedings. Case-Laws Income Tax Thu, 14 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762110