PAISALO DIGITAL LIMITED,NEW DELHI vs. DCIT CENTRAL CIRCLE 6, NEW DELHLI

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ITA 405/DEL/2025Status: DisposedITAT Delhi30 June 2025AY 2020-21Bench: Sh. Satbeer Singh Godara, Judicial Member & Sh. S. Rifaur Rahman (Accountant Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that due to communication gaps, especially with the introduction of virtual hearings, the assessee could not present their case effectively. It also noted a lack of compliance with Section 250(6) of the Act in the lower appellate order.

What were the facts?

The assessee's appeals arose from orders related to assessment years 2013-14, 2018-19 and 2020-21. The appeals were against the CIT(A)'s order passed in proceedings under Section 147 r.w.s. 144 and Section 143(3) r.w.s. 144B of the Income Tax Act, 1961.

What were the issues?

Whether the appeals should be restored to the CIT(A)/NFAC for fresh adjudication due to communication gaps and non-compliance with procedural requirements.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 143(3),Section 144B,Section 250(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘B’, NEW DELHI

Before: Sh. Satbeer Singh Godara & Sh. S. Rifaur Rahman

Hearing: 30.06.2025Pronounced: 30.06.2025

Heard together (3 matters)

ITA No. 404/Del/2025
ITA No. 407/Del/2025
ITA No. 405/Del/2025

Read from the judgment's own cause title. This page is filed under one of them.

Asstt. Year : 2020-21 Paisalo Digital Ltd., Vs DCIT, CSC Pocket-52, C. R. Park, Near Circle-6, Police Station Alaknanda, New Delhi-110001 New Delhi-110019 (APPELLANT) (RESPONDENT) PAN No. AACCS1879G Assessee by: Sh. S. K. Chaturvedi, CA Revenue by : Sh. Rajesh Kumar Dhanesta, Sr. DR Date of Hearing: 30.06.2025 Date of Pronouncement: 30.06.2025 ORDER Per Satbeer Singh Godara, Judicial Member: These assessee’s three appeals 405 & 407/Del/2025 for Assessment Years 2013-14, 2018-19 and 2020-21, arise against the CIT(A)-24, New Delhi’s DIN & order No.ITBA/APL/M/250/2024-25/1071072389(1), 1071072509(1) and 1071072590(1) dated 10.12.2024, in proceedings u/s 147 r.w.s. 144 (first case) and 143(3) r.w.s. 144B of the Income Tax Act, 1961 (in short “the Act”), respectively.

2.

Heard both the parties at length. Case files perused.

405 & 407/Del/2025 Paisalo Digital Ltd. 3. 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, in the larger interest of justice met in case, the matter be restored back to the CIT(A)/NFAC.

4.

Be that as it may, the fact remains that possibility of some communication gaps at various levels in such an instance of the newly introduced virtual hearing mechanism could not be altogether ruled out. This is indeed coupled with the facts that there is also no compliance to section 250(6) of the Act in the impugned lower appellate order stipulating points of determination to be framed followed by a detailed adjudication thereupon. It is therefore deemed appropriate in the larger interest of justice to set aside the assessee’s instant appeal back to the CIT(A)/NFAC for his afresh appropriate adjudication, within three effective opportunities of hearing at the appellant’s risk and responsibility, in consequential proceedings. Ordered accordingly.

405 & 407/Del/2025 Paisalo Digital Ltd. 5. These assessee’s three appeals 405 & 407/Del/2025 are allowed for statistical purposes. A copy of this common order be placed in the respective case files. Order Pronounced in the Open Court on 30/06/2025.

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