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Judgment
PER SATBEER SINGH GODARA, JM
These assessee’s seven appeals ITA Nos. 2664 to 2670/Del/2026 pertaining assessment years 2018-19, 2019-20, 2020-21 arise against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s orders, all dated 19.01.2026, having DINs and orders no. ITBA/NFAC/S/250/2025-26/1084913147(1), 1084913715(1), 1084914099(1), 1084920014(1), 1084921242(1), 1084920578(1) & 1084916038; respectively. The appeals ITA Nos.2664 to 2666/Del/2026 for AY 2018-19 involve the proceedings u/s 143(3), 271AAC1 and 271D of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’); ITA Nos. 2667 to 2669/Del/2026 for AY 2019-20 involve the proceedings u/s 147 r.w.s. 144, 270A and 271B; and the appeal ITA No.2670/Del/2026 for AY 2020-21 involve the proceedings u/s 147 r.w.s. 144; respectively.
Heard both the parties. 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 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 interest of justice to restore the assessee’s all the seven 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 seven appeals ITA Nos.2664 to 2670/Del/2026 are allowed for statistical purposes. A copy of this common order be placed in the respective case files.