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Judgment
This is a batch of two appeals pertaining to the same assessee, for AYs 2019-20 and 2020-21.
ITA No.5920 arises from order dated 21.03.2026, passed by Ld. CIT(A)-26, Delhi, u/s 250 of the Income Tax Act, 1961 (hereafter as “the Act”). ITA No.5921 pertaining to AY 2020-21 arises from order dated 09.04.2026, passed by Ld. CIT(A)-26, Delhi, u/s 250 of the Act.
In both the cases a penalty u/s 271DA of the Act has been levied as under: -
For AY 2019-20 a penalty of Rs.207,80,000/- has been levied;
ii) For AY 2020-21 a penalty of Rs.80,97,000/- has been levied.
Right at the outset, the Ld. AR made a statement at the Bar that the quantum matters for both the years were pending at the level of CIT(A) and it was a prayer that either these cases may be adjourned sin-e-die for awaiting the Ld. CIT(A)’s orders or alternatively these matters may be remanded back to the file of Ld. CIT(A) for adjudication along with the quantum matter.
The Ld. DR had no objection in case the matters were to be remanded back to the file of Ld. CIT(A).
We have considered the rival submissions and have gone through the records before us. It is felt that the decision in quantum would have some bearing on the penalties levied for both the years. Accordingly, we deem it fit to set aside the impugned orders for both the matters and remand the same back to the file of Ld. CIT(A) for adjudication along with the quantum matters.
In the result, these appeals are partly allowed for statistical purposes.