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Judgment
These are a batch of seven appeals filed by the Revenue in which there has been no presence recorded on behalf of the assessee over the course of several hearings, including the last hearing, in the case. In this matter the Revenue had been asked to serve the notice on the assessee on at least two occasions in the past.
On the last date of hearing, the Ld. DR presented a report from the ACIT, Circle 1(2)(2), International Taxation, New Delhi as under: -
“Respected Sir/Ma’am, Kindly refer to the trailing mails in the above-mentioned matter. In this regard, it is respectfully submitted that the Hon'ble Bench had directed for Dasti service of notice on the assessee and later on the CA/Counsel of the assessee, as available on record, through the Department. The Hon'ble Bench further directed that the notice be served on the CA/Counsel of the assessee and that proof of such service be furnished to this office. In compliance with the aforesaid directions, it is stated that no possible address in India of the assessee is available with this office as per records. The two addresses available are of UAE, where the notice has been sent vu post. Further, since no response has been received, an email has been sent dated 08.04.2026 and 29.04.2026 to all possible email addresses of the assessee available on system. This office despite persistent efforts has not been able to get contact details of the current CA/Counsel of the assessee. The CA who represented the case in CIT(A) is no longer associated with the assessee. It is further submitted that is notice has been sent to the assessee via ITBA Portal on 29.04.2020 intimating the next date of hearing fixed by the Hon'ble Bench, i.e., 05.05.2026 along with the notice of the ITAT attached.”
The Ld. AR stated that the Ld. AO was unable to trace out the assessee for any meaningful service of notice.
We have carefully considered the case files available with us and have also perused the report of the AO regarding his inability to service the notice of hearing in this case. It is important to record that ever since the first hearing in this matter there has been no representation on behalf of the assessee and now it transpires that there is no reasonable possibility of getting the notice of hearing served on the assessee. Accordingly, we are constrained to dismiss the seven appeals at this stage, with liberty to the Revenue to seek revival of these appeals in case the assessee is eventually traced out.
In the result, all the seven appeals are hereby dismissed, with liberty to the Revenue as mentioned above.