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Judgment
PER SATBEER SINGH GODARA, JM
These assessee’s five appeals ITA Nos.2651 to 2655/Del/2026 pertaining to assessment year 2022-23 arise against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s, all dated 19.01.2026, having DINs and orders no. ITBA/NFAC/S/250/2025-26/1084924456(1), 1084925024(1), 1084925510(1), 1084926005(1) and 1084925779(1), involving proceedings under sections 144, 270A, 271AAC1, 271B and 272A(1)(d) 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 matter s may be restored back to the CIT(A) /NFAC. 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 of the newly introduced virtual hearing mechanism could not be altogether ruled out. It is therefore deemed appropriate in the larger int erest of justice to restore the assessee’s all the five appeals back to the CIT(A)/NFAC for their afresh appropriate adjudication, within three effective opportunities of hearing at the appellant’s risk and responsibility, in consequential proceedings. Ordered accordingly.
These assessee’s five appeals ITA Nos. 2651 to 2655/Del/2026 are allowed for statistical purposes. A copy of this common order be placed in the respective case files.