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Judgment
ORDER
This assessee’s appeal for Assessment Year 2020-21 arises against the C IT(A)/NFAC, De lhi’ s DIN & order No. ITBA/NFAC/S/250/2025-26/1082974326(1) dated 25.11.2025, in proceed ings u/s 147 of the Income Tax Act, 1 961 (in short “the Act”).
Heard both the p arties at length. Case file perused.
Learned counsel submits that on account of communicatio n gaps at various levels, the assessee could not appear to plead and prove all the relevant facts in the lower appellate proceedings and there fore, in the large r interest of justice met in case, the matte r be restored back to the CIT(A)/NFAC .
Be that as it may, the fact remains that possibility of some co mmunication gaps at various levels in such an instance of the new ly introduced virtual he aring me chanism could not be altogether ruled out. T his is indeed coupled with the facts that there is also no effective compliance to section 2 50(6) of the Act in the impugned lower appellate order stipulating points of determinatio n to be framed followed by a detailed adjudication thereupon. It is therefore deemed appropriate in the larger interest of justice to set aside the asse ssee’s instant appeal back to the CIT(A)/NFAC for his afresh appropriate adjudicatio n, w ithin three effective opportunities of he aring at the appellant’s risk and responsibility, in consequential proceedings. Ordered accord ing ly.
This assessee’s appeal is allowed for statistical purposes.
