Kashmir Kaur vs National Faceless Appeal Centre (NFAC)

PER SATBEER SINGH GODARA, JM:

This assessee’s appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2026-27/1089125833(1), dated 21.05.2026 involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.

It transpires during the course of hearing that the assessee/appellant is aggrieved against both the learned lower authorities’ respective assessment and lower appellate findings making section 69 unexplained investment addition of Rs. 13,74,557/- which forms the sole substantive issue for the tribunal’s apt adjudication herein.

That being the case, it is noticed from a perusal of the case record that the assessee had sought to explain for source of her jewellery sold as well as alleged unexplained investments by way of filing her additional evidence under Rule 46A of the Income Tax Rules, in the lower appellate proceedings which has been summarily rejected therein. The Revenue could hardly dispute that the assessee’s additional evidence indeed goes to the root of the matter and possibility of some communication gaps in such an instance could not be per se ruled out. It is thus deemed appropriate in the larger interest of justice to admit the assessee’s above additional evidence and direct the learned CIT(A)/NFAC_to get the necessary remand report from the field authorities subject to a rider that the tax payer/appellant herein shall plead and prove her case within three effective opportunities at her own risk and responsibility in the consequential proceedings. All other remaining issues between the parties are kept open at this stage.

This assessee’s appeal is allowed for statistical purposes.