आयकर अपील(cid:547)य अ(cid:876)धकरण Ûयायपीठ रायपुर म(cid:581)।

IN THE INCOME TAX APPELLATE TRIBUNAL, RAIPUR BENCH, RAIPUR BEFORE SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER आयकर अपील सं. / ITA Nos.52, 53, 54, 55 & 339/RPR/2025 (cid:467)नधा(cid:91)रण वष(cid:91) / Assessment Years : 2015-16, 2016-17, 2017-18 & 2018-19 Shri Shyam Oil Extractions Pvt. Ltd.

Village: Banari, Janjgir, Janjgir-Champa (C.G.)-495 668 PAN: AAOCS2467G ........अपीलाथ(cid:568) / Appellant बनाम / V/s.

The Income Tax Officer/ACIT-2(1), Ward-Janjgir-Champa (C.G.)/Bilaspur ……(cid:292)×यथ(cid:568) / Respondent Assessee by : Shri R.B Doshi, CA Revenue by : Shri Yogesh Kumar Sharma, CIT-DR &

Dr. Priyanka Patel, Sr. DR सुनवाई क(cid:551) तार(cid:547)ख / Date of Hearing : 03.02.2026 घोषणा क(cid:551) तार(cid:547)ख / Date of Pronouncement : 05.02.2026 आदेश / ORDER PER PARTHA SARATHI CHAUDHURY, JM:

The captioned appeals preferred by the assessee emanates from the respective orders of the Ld.CIT(Appeals)-3, Raipur dated 28.11.2024, 29.11.2024 and 31.03.2025 for the assessment years 2015-16 to 2018-19 as per the grounds of appeal on record.

2. At the very outset, parties herein conceded that the facts and issues involved in all these appeals are similar in nature. Having heard the submissions of the parties herein, all these matters are heard together and disposed off vide this consolidated order.

3. The Ld. Counsel for the assessee submitted that in ITA Nos. 52, 53 & 54/RPR/2025, A.Ys. 2015-16, 2016-17 & 2017-18, an ex-parte order has been passed by the Ld. CIT(Appeals) and the assessee was unable to represent their matters before the first appellate authority due to unavoidable circumstances which has been explained by him through written submission which is extracted as follows:

We do not find any deliberate or malafide conduct on the part of the assessee for such non-compliance before the Ld. CIT(Appeals).

4. That admittedly, the assessee has complied with the directives of the Hon’ble Jurisdictional High Court. That even the Revenue authorities have not brought on record any evidence to suggest any deliberate or malafide conduct on the part of the assessee for such non-compliance of the hearing notices which resulted in ex-parte order. That so far as ITA No.52/RPR/2025 is concerned, Para 3 of the order of the Ld. CIT(Appeals) evidences the fact of ex-parte order being passed by the said authority and the same is extracted as follows:

“3. The appeal was fixed for hearing on 22.12.2021, 08.03.2022 in response submit through ITBA to the above notice the appellant had requested adjournment for submission. Hence the adjournment was granted is accorded notice u/s. 250 again issued vide dt. 20.02.2022 and the appeal was fixed for hearing on 07.07.2022. The assessee reply submit through ITBA in response to the above notice the appellant again requested adjournment for submission. Further, again adjournment was granted is accorded notice u/s 250 again issued vide dt. 13.10.2022 and the appeal was fixed for hearing on 04.11.2022.The assessee reply submit through ITBA in response to the above notice the appellant again requested adjournment for submission. Further, again adjournment was granted is accorded notice u/s 250 again issued vide dt. 30.12.2022 and the appeal was fixed for hearing on 12.01.2023.The assessee reply submit through ITBA in response to the above notice the appellant again requested adjournment for submission. Further, again adjournment was granted is accorded notice u/s 250 again issued vide dt. 04.12.2023 and the appeal was fixed for hearing on 20.12.2023.The assessee reply submit through ITBA in response to the above notice the appellant again requested adjournment for submission. Further, again adjournment was granted and final opportunity is accorded notice u/s 250 again issued vide dt. 14.11.2024 and the appeal was fixed for hearing on 20.11.2024. It is quite evident from the chronology of event that despite sev