Ginni Devi vs The Deputy Commissioner Of Income Tax

These assessee’s four appeals for assessment years 2018-19, 2019-20, 2022-23 and 2023-24 arise against the Commissioner of Income Tax (Appeals-26), [in short, the “Ld. CIT(A)”], Delhi’s order all dated 13.04.2026 having DIN & Order No. ITBA/APL/S/250/2026-27/1088420958(1), 1088420738(1), 1088420477(1), and 1088420134(1) involving proceedings under section 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively.

Heard both the parties at length. Case files perused.

Learned counsel submits that on account of communication gaps at various levels, the assessee could not appear to plead and prove all the relevant facts in the lower appellate proceedings; and; therefore, the matter may be restored back to the CIT(A). The Revenue vehemently supports the learned lower authority’s action making the addition(s) herein on merits.

Be that as it may, the fact remains that possibility of some communication gaps at various levels in such an instance could not be altogether ruled out. It is therefore deemed appropriate in the larger interest of justice to restore the assessee’s instant appeals back to the learned CIT(A) for his afresh appropriate adjudication, within three effective opportunities of hearing at the appellant’s risk and responsibility, in consequential proceedings. Ordered accordingly.

These assessee’s four appeals ITA Nos. 5836 to 5839/Del/2026 are allowed for statistical purposes. A copy of this common order be placed in the respective case files.