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Judgment
PER BENCH
All these appeals are filed by the assessee against the common order of the Ld. CIT(A)-3, Gurgaon dated 14.08.2025 for the A.Y. 2016-17 to 2018-19 and common order of the Ld. CIT(A)-3, Gurgaon dated 14.08.2025 for the A.Y. 2019-20 to 2021-22.
In all these appeals the assessee has raised various grounds in sustaining the additions made while completing the assessment u/s.153C of the Act by the AO. Also challenged the order of the Ld. CIT(A) in disposing of these appeals exparte without providing adequate opportunity to the assessee and in violation of principle of natural justice.
The Ld. Counsel for the assessee at the outset submitted that all these appeals were disposed of by the Ld. CIT(A) without providing adequate opportunity to the assessee. The Ld. Counsel submitted that the appeals of the assessee were also dismissed without admitting the application under Rule 46A for admission of additional evidences. The Ld. Counsel further submitted that even during the assessment proceedings the assessee could not submit the evidences and explain the cash deposits, therefore, the Ld. Counsel for the assessee submitted that an opportunity may be given to the assessee to explain the cash deposits in bank account to the AO.
On the other hand the Ld. DR has no objection in restoring the appeals to the file of the AO for denovo assessment.
On hearing both the sides and perusing the orders of the authorities below we are of the view that these appeals should go back to the file for the AO for fresh assessment after providing adequate opportunity of being heard to the assessee. The assessee shall cooperate with the AO in the assessment proceedings and may furnish necessary details in support of the contentions.
In the result, all the appeals of the assessee are allowed for statistical purpose.