2026 (3) TMI 1123

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....nding Counsel for the respondent. 2. These appeals are filed by the assessee challenging the order dated 04.06.2024 passed by the Income Tax Appellate Tribunal, 'C' Bench, Bengaluru (for short, 'the Tribunal') in ITA Nos. 699 to 704/Bang/2024. 3. The assessee failed to furnish returns of income for the Assessment Years 2013-14 and 2014-15. Consequently, the Assessing Officer reopened the assessments by issuance of notice under Section 148 of the Income Tax Act, 1961 (for short, 'the Act'). The assessee failed to file returns of income even in response to the notice issued under Section 148 of the Act. Thereafter, the Assessing Officer completed the assessments under Sections 147/144 read with Section 144B of the Act on 23.03.2022 and ....

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....ice of notices; however, the notices were not issued to the said secondary email ID. 6.1 Learned counsel also submits that, in the absence of participation by the assessee in the assessment proceedings, the Assessing Officer proceeded to consider the entire gross receipts and levied tax. It is further submitted that the CIT(A) as well as the Tribunal, without considering the reasonable explanation offered for the delay, committed an error in rejecting the appeals solely on the ground of delay. 7. Sri Aravind V. Chavan, learned Senior Standing Counsel appearing for the Revenue, submits that the assessee is required to furnish a valid email ID in the return of income filed. The Assessing Officer issued notices to the email ID furnished ....

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....ground. 11. We are inclined to interfere with the appeals to the limited extent of granting an opportunity to the assessee to participate in the appellate proceedings and redress its grievance before the CIT(A). Though the learned counsel for the appellant sought a remand of the matter for fresh adjudication by the Assessing Officer, we are not inclined to grant such relief. The assessee was required to file returns of income and, having failed to do so, the statutory window for filing returns cannot be reopened at this length of time. 12. The appellate proceedings before the CIT(A) are in continuation of the assessment proceedings, and the assessee would have sufficient opportunity to place its case before the CIT(A). 13. Insofar ....