ITAT Remanded Matter as CIT(A) Dismissed All Grounds of Appeal Based on a Single Issue

Case Details: Computer Sciences Corporation India (P.) Ltd. v. DCIT - [2024] 163 taxmann.com 693 (Hyderabad-Trib.)

Judiciary and Counsel Details

• • K. Narasimha Chary, Judicial Member & Madhusudan Sawdia, Accountant Member
  • Vikram Vijayaraghavan, AR for the Appellant.
  • Kumar Pranav, CIT-DR for the Respondent.

Facts of the Case

The assessee was a private limited company engaged in software development. During the year under consideration, the assessee filed its return of income under the normal provisions of the Income-tax Act and declared book profits under section 115JB of the Act.

The case was selected for scrutiny, and notices were issued to the assessee. The Assessing Officer (AO) completed the assessment under section 143(3) of the Act, determining the total income under the normal provisions of the Act and book profit under section 115JB.

On appeal, CIT(A) consolidated all the grounds of appeal into a single issue and disposed of the appeal. Aggrieved-assessee filed the instant appeal before the Tribunal.

ITAT Held

The Hyderabad Tribunal held that the CIT(A) adjudicated the grounds on only one issue, i.e., whether the comparables are valid or not, and dismissed the grounds on all the other issues without considering the merits.

The CIT(A) held that assessee failed to furnish any evidence/documents before him. However, the relevant portion of the order of CIT(A) clearly mentioned that the assessee had filed all the necessary documents and evidence before him.

Accordingly, the Tribunal deemed it appropriate to remit the issue back to the file of the CIT(A) with a direction to look into the facts and decide the issue as per law by giving the assessee an opportunity to be heard.