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Judgment
ORDER
This assessee’s appeal for Assessment Year 2011-12, arises against the C IT(A)/NFAC, Delhi’s DIN & Order No.IT BA/ NFAC/ S/250/2025-26/1082061015(1) date d 28.10.2025 in proceedings u/s 144 of the Inco me Tax Act, 1961 (in short “ the Act”).
Heard both the p arties. Case file perused.
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, the matter be restored back to the CIT(A)/NFAC. The Revenue vehemently supports the lear ned lower author ity’s action making the addition(s) herein on merits.
Be that as it may, the fact remains that possibility of some co mmunication gaps at various levels in such an instance of the new ly introduced virtual he aring me chanism could not be altogether ruled out. It is therefore deemed appropriate in the larger interest of justice to restore the assessee’s instant appeal back to the CIT(A)/ NFAC for his fresh appropriate adjudicatio n, w ithin three effective opportunities of he aring at the appellant’s risk and responsibility, in consequential proceedings. Ordered accord ing ly.
This assessee’s appeal is allowed for statistical purposes.