W L D INVESTMENTS PRIVATE LIMITED,DELHI vs. DCIT CIRCLE 25(1), DELHI

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ITA 5844/DEL/2026Status: DisposedITAT Delhi23 September 2026AY 2021-223 pages
AI SummaryAllowed

What did the Tribunal hold?

The ITAT, while noting the assessee's non-compliance, remanded the matter back to the CIT(A) for fresh adjudication to ensure natural justice. The assessee was directed to comply with all future notices and provide required documents.

What were the facts?

The assessee's appeal against the disallowance of bad debts was dismissed ex-parte by the CIT(A) due to non-compliance with notices. The assessee contended that proper and adequate opportunity of being heard was not provided.

What were the issues?

Whether the CIT(A) erred in disposing of the appeal ex-parte without providing adequate opportunity of being heard, in contravention of Section 250(6), and confirming the disallowance of bad debts.

Which sections of the Income-tax Act were involved?

Section 250(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCHES ‘E’: NEW DELHI

Before: SHRI MAHAVIR SINGH & SHRI KRINWANT SAHAY

Hearing: 13.08.2026Pronounced: 13.08.2026

PER KRINWANT SAHAY, AM:

Appeal in this case has been filed by the assessee against the order dated 28.11.2025 passed by the ld. CIT(A) NFAC, Delhi for Assessment Year: 2021-22. 2. Grounds of appeal taken by the assessee are as under:

“1. On the facts and in the circumstances of the case and in law, National Faceless Appeal Centre ('NFAC') erred in disposing off the appeal before it without providing proper and adequate opportunity of being heard.

2 ITA No. 5844/Del/2026 WLD Investments Pvt. Ltd. 2. On the facts and in the circumstances of the case and in law, National Faceless Appeal Centre ('NFAC') erred in passing order dated 28.11.2025 in contravention of the mandate in section 250(6) of the Act. 3. On the facts and in the circumstances of the case and in law, National Faceless Appeal Centre ('NFAC') erred in confirming disallowance of Bad Debts aggregating Rs.1,68,56,476/-. 4. The Assessee seeks leave to add to, forego, alter, or otherwise modify all or any of the grounds of appeal as raised herein above.”

3.

At the very outset, the ld. counsel of the assessee brought it to the notice of the Bench that the ld. CIT(A) dismissed the appeal of the assessee ex-parte and he requested that the matter may be remanded back to the ld. CIT(A) for fresh adjudication. 4. Per contra, the ld. DR relied on the order of the ld. CIT(A).

5.

We have considered the findings given by the ld. CIT(A) in the appellate order and we find that despite the fact that the ld. CIT(A) has given many opportunities to the assessee of being heard but the assessee did not comply with any notices issued by the ld. CIT(A). Still then, we are of this considered view that keeping in mind, the element of natural justice, the assessee deserves one more opportunity of being heard. Accordingly, we remand this back to the file of the ld. CIT(A) for fresh adjudication after giving adequate opportunity to the assessee as required under law.

3 ITA No. 5844/Del/2026 WLD Investments Pvt. Ltd. The assessee is also directed to comply with the notices of the ld. CIT(A) and file all the required documents and details in time.

6.

In the result, the appeal filed by the assessee is allowed for statistical purposes.

Order pronounced in the Open Court on 13.08.2026

Sd/- Sd/- (MAHAVIR SINGH) (KRINWANT SAHAY) VICE PRESIDENT ACCOUNTANT MEMBER Dated: 23.09.2026 *GP/Sr.PS* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT(E) 4. CIT 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI

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