IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER (Hybrid Hearing)

Sl. ITA Nos. Asst. Name of Appellant Name of No. Years Respondent (AY)

1. 810/SRT/2024 2011-12 Altret Industries Pvt. Ltd., ITO, 12/2881, Altret House, TDS, CPC Saiyedpura Main Road, Gujarat – 395003 PAN: AAECA7918E

2. 811 to 2013-14 Altret Industries Pvt. Ltd., ITO, 812/SRT/2024 12/2881, Altret House, TDS, CPC Saiyedpura Main Road, Gujarat – 395003 PAN: AAECA7918E

3. 814 to 2015-16 Altret Industries Pvt. Ltd., ITO, 815/SRT/2024 12/2881, Altret House, TDS, CPC Saiyedpura Main Road, Gujarat – 395003 PAN: AAECA7918E

4. 816 & 2014-15 Altret Industries Pvt. Ltd., ITO, 818/SRT/2024 12/2881, Altret House, TDS, CPC Saiyedpura Main Road, Gujarat – 395003 PAN: AAECA7918E

5. 855/SRT/2024 2016-17 Altret Industries Pvt. Ltd., ITO, 12/2881, Altret House, TDS, CPC Saiyedpura Main Road, Gujarat – 395003 PAN: AAECA7918E Appellant by Shri Kishor Gheewala, CA Respondent by Shri Ajay Uke, Sr. DR Date of Hearing 23/07/2025 Date of Pronouncement 25/07/2025 आदेश / O R D E R PER BIJAYANANDA PRUSETH, AM:

These appeals by the assessee emanate from the separate orders, all dated 04.06.2024, passed under section 250 of the Income-tax Act, 1961 (in short, ‘the Act’) by the learned Addl./Jt. Commissioner of Income-tax (Appeals) - 9, Delhi [in short, ‘the CIT(A)’] for the different assessment years (AYs) 2011-12, 2013-14, 2014-15, 2015-16 and 2016-17. All these appeals before the CIT(A) were against orders passed u/s 200A(1) of the Act by the TDS, CPC, Bengaluru for the above years. Since facts are same, with consent of both parties, the cases were heard together and a common order is passed for the sake of convenience and brevity. ITA No.810/SRT/2024 for AY.2011-12 is taken as ‘lead’ case.

2. The grounds of appeal raised by assessee in ‘lead’ case are as follows:

“1. The learned ADDL/JCIT(A) has grossly erred in not condoning the delay &

dismissing the appeal ex-party.

2. The Ld. Assessing officer (TDS - CPC) has grossly erred in holding short payment of Rs.10,750/- and levying consequential interest of Rs.3,420/-

charged on same, resulting in erroneous demand of Rs.14,170/-.

3. The deductees have received TDS certificates from the appellant, which they have used to claim credit for TDS while filing their income tax returns. If in any instance, there was a shortfall in TDS payment, it would have been paid by respective taxpayers through self-assessment tax payments. Thus, there has been no loss of tax revenue, and the tax liability has been wrongly thrust upon the appellant.

4. Furthermore, the appellant has not been communicated any instance for Short Deduction of TDS of deductees & therefore also the demons is illegal.

5. In absence of any revenue loss, levy of Interest is also absolutely unwarranted and liable to be quashed as illegal.

6. The said demand is liable to be deleted by giving the Benefit of Proposal of withdrawal of outstanding direct tax demands provided in Order No.

375/02/2023 IT Budget Dt. 13.02.2024 and also liable to take benefit of Vivad se Vishwas Scheme, 2024 as stated in BUDGET 2024-2025.

7. The appellant Craves leave to add, to alter or amend present grounds of Appeal.”

3. The facts of the case in brief are that the assessee is a private limited company. The assessee company was engaged in the business of manufacturing of and supply of water and fuel treatment chemicals, hygiene care products and cleaning solutions etc. As per the ‘Statement of Facts’, the assessee had filed its TDS quarterly statement of FY.2010-11. The TDS - CPC (in short, ‘AO’) raised demand of Rs.14,170/- due to short payment of tax of Rs.10,750/- and consequential interest of Rs.3,240/-.

4. Aggrieved by the order of AO, the assessee filed appeals before the CIT(A). The CIT(A) issued 4 notices, which is at para 2 of the appellate order. There was non-compliance on the part of the appellant. Since the appeal was