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Judgment
PER SATBEER SINGH GODARA, JM
These assessee’s three appeals ITA No. 7440 to 7442/Del/2025 for assessment years 2014-15, 2015-16 & 2019-20, arise against the Principal Commissioner of Income Tax (Appeals)-25 [in short, the “PCIT(A)”], New Delhi’s orders, all dated 10.11.2025, having DINs and orders no. ITBA/APL/M/250/2025-26/1082420519(1), ITBA/APL/M/250/2025-26/1082420703(1) and ITBA/APL/M/250/2025-26/1082420956(1), involving proceedings under section 153C of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), 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, larger interest of justice would be met, in case, the matter s may be restored back to the PCIT(A). The Revenue vehemently support the learned lower authorities action making 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 three appeals back to the PCIT(A) for its afresh appropriate adjudication, within three effective opportunities of hearing at the appellant’s risk and responsibility, in consequential proceedings. Ordered accordingly.
These assessee’s three appeals ITA Nos.7440 to 7442/Del/2025 are allowed for statistical purposes. A copy of this common order be placed in the respective case files.