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Judgment
ORDER
PER SATBEER SINGH GODARA, JM
This assessee’s appeal for assessment year 2019-20, arises against the Commissioner of Income Tax (Appeals)-30 [in short, the “CIT(A)”], New Delhi’s order dated 11.11.2025 having DIN and order no. ITBA/APL/M/250/2025-26/1082456631(1), involving proceedings under section 147 r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file 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 matters 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 between the taxpayer, auditor and the arguing counsel 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 appeal back to the CIT(A) for its afresh appropriate adjudication, within three effective opportunities of hearing at the appellant’s risk and responsibility, in consequential proceedings. Ordered accordingly.
This assessee’s appeal is allowed for statistical purposes.