Corporate TaxArticle·5 September 2026
ITAT says Faceless Allocation Cannot Take Away the Right to Appeal
By J the App
Executive Summary
PRA Panels had claimed the concessional 15% tax rate under Section 115BAB after filing the prescribed Form 10-ID, but the CPC denied the claim.
When the assessee challenged the subsequent Section 154 order, the JCIT rejected the appeal as not maintainable under Section 246. The ITAT held that the assessee could not be prejudiced by the Department's internal functioning under the faceless regime and restored the matter for fresh adjudication on the Section 115BAB claim, in accordance with natural justice.
Domain: DT | Corporate Tax
The Position
PRA Panels had filed its return...
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