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Judgment
PER SATBEER SINGH GODARA, JM
These assessee’s six appeals ITA Nos.5663/Del/2025 and 5579 to 5583/Del/2025 with the Revenue’s cross appeal ITA No. 6364/Del/2025 for assessment years 2014-15 to 2019-20 arise against the Commissioner of Income Tax (Appeals)-30 [in short, the “CIT(A)”], New Delhi’s orders, all dated 30.06.2025 having DINs: ITBA/APL/M/2025/2025-26/1078012147, 1078013331(1), 1078013557(1), 10780113887(1), 1078014094(1), 1078014280(1), respectively involving proceedings under section 153A/143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case files perused.
Delay of 8 days in filing of the Revenue’s cross appeal ITA No.6364/Del/2025 is condoned in larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).
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 matters may be restored back to the CIT(A). The Revenue vehemently support the learned lower authorities action making addition(s) herein on merits. It further seeks to reverse the CIT(A)’s findings estimating the assessee’s commission income in AY 2019-20.
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 six appeals as well as the Revenue’s sole case herein; back to the CIT(A) for his afresh appropriate adjudication, within three effective opportunities of hearing at the appellant’s risk and responsibility, in consequential proceedings. Ordered accordingly. The assessee’s six appeals ITA Nos.5663/Del/2025 and 5579 to 5583/Del/2025 as well as the Revenue’s case ITA No.6364/Del/2025 are allowed for statistical purposes
To sum up, these assessee’s six appeals ITA Nos.5663/Del/2025 and 5579 to 5583/Del/2025 and Revenue’s cross appeal ITA Nos. 6364/Del/2025 are allowed for statistical purposes. A copy of this common order be placed in the respective case files.