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Judgment
PER MADHUMITA ROY, J. M.:
Both the Appeals filed by the different assessees are directed against the orders both dated 19.12.2025 passed by the Learned Commissioner of Income Tax (Appeals), New Delhi passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) arising out of the assessment orders dated 26.03.2022 and 24.03.2022 respectively under Section 143(3) of the Income Tax Act, 1961 for Assessment Year 2021-22.
Both the appeals filed by the different assessee’s since relate to the same issue, these are heard analogously and are being disposed of by a common order.
The impugned order passed by the Ld. CIT(A) is ex-parte orders as none appeared on behalf of the assessee, inspite of notices having been served. It is the case of the assessee that the notices at the subsequent stages by the Ld. CIT(A) was not sent to the actual mail-id belongs to the assessee; in-fact it was candidly submitted by the Ld. AR that the assessee’s mail id was subsequently changed. The notice having not been sent to the said e-mail id, the matter could not be represented. However, he has undertaken to provide the correct mail id to the Ld. CIT(A). In that view of the matter, he prays for a further opportunity to the assessee to represent its case effectively to the Ld. CIT(A). Such prayer has not been objected by the Ld. DR with all his fairness.
Having heard the Ld. Counsels appearing for the parties and having regard to the facts and circumstances of the matter, we dispose of these appeals by setting aside the same to the file of the Ld. CIT(A) for fresh adjudication on the merit of the matters. He is further directed to grant an opportunity of being heard to the assessee while considering the case made out by the assessee and to finalize the issue by passing a reasoned order upon considering the evidence on record or any other evidence which the assessee may choose to file at the time of hearing of the matters.
In the result, both the Appeals filed by the assessees are allowed for statistical purposes.