#ITAT Raipur

The ITAT Raipur bench ruled that dismissing an income tax appeal solely due to delay, without affording the appellant an opportunity to explain the reason, violates fundamental principles of natural justice. This sets a critical precedent for taxpayers and tax authorities alike: procedural fairness trumps technical non-compliance when substantive rights are at stake.

ITAT Raipur ruled that revenue authorities cannot alter their position on identical factual matrices across assessment years without material change, setting aside a ₹64.32 lakh addition. The decision reinforces the binding nature of the 'principle of consistency' for tax assessments, protecting assessees from arbitrary reassessments.