ROYAL VALTRANS INDIA PRIVATE LIMITED,DELHI vs. ASSESSMENT UNIT, DELHI
What did the Tribunal hold?
The tribunal condoned the delay and restored the appeal to the CIT(A)/NFAC for fresh adjudication. This was due to the possibility of communication gaps in the new virtual hearing mechanism, in the interest of justice.
What were the facts?
The assessee's appeal for AY 2020-21 was filed with a delay of 129 days. The assessee claimed communication gaps prevented them from presenting all facts in lower appellate proceedings.
What were the issues?
Whether the assessee was prevented by sufficient cause from appearing before the lower appellate authority due to communication gaps in the virtual hearing process.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI SANJAY AWASTHI
PER SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER:
This assessee’s appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN ITBA/NFAC/S/250/2025-26/1082586159(1), and order no. dated
11.11.2025 involving proceedings under section 147 of the Income- tax Act, 1961; hereinafter referred to as ‘the Act’.
ITA 6489/DEL/2026 ROYAL VALTRANS INDIA PRIVATE LIMITED Heard both the parties. Case file perused.
For the reasons stated in the assessee’s condonation averments, delay of 129 days in filing of the instant appeal is condoned in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).
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, the matter may be restored back to the CIT(A)/NFAC. The Revenue vehemently supports the learned lower authorities’ action making the addition(s) herein on merits.
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. 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 afresh appropriate adjudication,
ITA 6489/DEL/2026 ROYAL VALTRANS INDIA PRIVATE LIMITED within three effective opportunities of hearing at the appellant’s risk and responsibility, in consequential proceedings. Ordered accordingly.
This assessee’s appeal is allowed for statistical purposes. Order pronounced in the open court on 9th September, 2026.
Sd/- Sd/- SANJAY AWASTHI SATBEER SINGH GODARA ACCOUNTANT MEMBER JUDICIAL MEMBER New Delhi Dated: 21.09.2026 Pooja Mittal, Sr. PS Copy to: ROYAL VALTRANS INDIA PRIVATE LIMITED , 4-C, GROUND FLOOR, SIDE BHARAT 1 NAGAR MARKET, ZAKIR NAGAR, SOUTH EAST DELHI, DELHI-110025, DELHI ASSESSMENT UNIT, ASSESSMENT UNIT, NATIONAL 2 FACELESS ASSESSMENT CENTRE, DELHI-110002, DELHI
3 THE PCIT / CIT, 4 THE D.R., ITAT, DELHI BENCH 5 GUARD FILE TRUE COPY
ASSISTANT REGISTRAR
More judgments on Section 147
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Tarunaben Maganlal Bhut, Navagam vs ITO Ward 2(2)(1), RajkotITA 673/RJT/2026[2024-25]Status: Disposed21 Oct 2026AY 2024-25
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
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