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Judgment
All these appeals are filed by the assessee against the common order of the Ld. CIT(A)-3, Gurgaon dated 14.08.2025 for the A.Y. 2011-12 to 2014-15 and different orders of the Ld. CIT(A)-3, Gurgaon dated 14.08.2025 for the A.Y. 2015-16 to 2020-21.
In all these appeals the assessee has raised various grounds in sustaining the additions made while completing the assessment u/s.153C of the Act by the AO. Also challenged the order of the Ld. CIT(A) in disposing of these appeals exparte without providing adequate opportunity to the assessee and in violation of principle of natural justice.
The Ld. Counsel for the assessee at the outset submitted that all these appeals were disposed of by the Ld. CIT(A) without providing adequate opportunity to the assessee. The Ld. Counsel submitted that operations of the Assessee company were closed and therefore, the concerned person who was looking after the tax proceedings was not aware of the notices issued by the Ld. CIT(A), therefore, the Assessee could not respond to the notices. The Ld. Counsel for the assessee submitted that the appeals may restored to the file of the Ld.CIT(A) for providing adequate opportunity of being heard to the assessee.
On the other hand the Ld. DR has no objection in restoring the appeals to the file of the Ld. CIT(A) for deciding afresh.
On hearing both the sides and perusing the orders of the authorities below we are of the view that these appeals should go back to the file of the Ld. CIT(A) for fresh hearing after providing adequate opportunity of being heard to the assessee. The assessee shall cooperate with the proceedings before Ld. CIT(A) and may furnish necessary details in support of the contentions.
In the result, all the appeals of the assessee are allowed for statistical purpose.