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Judgment
Per Satbeer Singh Godara, Judicial Member:
These assessee’s four appeals in ITA Nos. 5029 to 5032/Del/2025 for Asse ssment Years 2018-19 to 2021-22, arise against the CIT(A)-3, Gurgaon’s commo n order dated 27.09.2024 in case Nos. 112 68, 11544, 11 942, 10832, 11059/CIT(A)-3/GGN/2014-15 to 2018-19, in proceedings u/s 153C of the Income Tax Act, 1961 (in short “the Act”), respectively.
Heard both the p arties at length. Case files peruse d.
Delay o f 262 d ays in filing of all these appeals are condoned in the larger interest of justice in light of Collector Land Acquisitio n vs. Mst. Katiji & Ors (1987) 167 ITR 471 (SC) .
Learned counsel submits that on account of communicatio n gaps at various levels, the assessee could not appear to plead and prove all the relevant facts in the lower appellate proceedings and there fore, in the large r interest of justice met in case, the matter be restored back to the CIT(A).
Be that as it may, the fact remains that possibility of some co mmunication gaps at various levels in such an instance could not be altogether ruled out. This is indeed coupled with the facts that there is also no effective comp liance to section 250(6) of the Act in the impugned lo wer appellate order stipulating points of determination to be framed followed by a detailed adjud ication thereupo n. It is therefore deemed appropriate in the larger interest o f justice to set aside the assessee’s all appeals back to the C IT(A) for his afresh appropriate adjudication, within three effective opportunities of hearing at the appellant’ s risk and responsibility, in consequential pr oceedings. Ordered accord ingly.
These assessee’s four appeals ITA Nos. 5 029 to 5032/Del/2025 are allowed for statistical purposes. A copy of this common order be placed in the respective case file s.