SONIA KHOSLA,PATIALA vs. INCOME TAX OFFICER, WARD-SAMANA, SAMANA, PATIALA

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ITA 113/CHANDI/2026Status: DisposedITAT Chandigarh03 August 20262 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal, considering the principles of natural justice, granted the assessee another opportunity to present its case. The impugned order was set aside, and the matter was restored to the Assessing Officer for a de-novo assessment.

What were the facts?

The assessee's appeal for AY 2020-21 arose from an assessment framed on a best judgment basis due to the absence of substantive representation. The Assessing Officer made an addition of unexplained expenditure under Section 69A, which was confirmed by the CIT(A).

What were the issues?

Whether the assessee should be granted another opportunity to substantiate its case before the Assessing Officer, given the assessment was made on a best judgment basis.

Which sections of the Income-tax Act were involved?

Section 69A,Section 147,Section 144,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2020-21 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC, [CIT(A)] dated 11.11.2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] on best judgment basis u/s 147 r.w.s. 144 r.w.s. 144B of the Act on 27.12.2024. In the assessment order, Ld. AO made addition of unexplained expenditure

u/s 69A for Rs.59.46 Lacs for want of any substantive representation from the assessee. The position remained the same before Ld. CIT(A) who confirmed the assessment. The only prayer of Ld. AR is another opportunity of hearing which has been opposed by Ld. Sr. DR. The Ld. AR has stated that the assessee is in a position to substantiate its case. 2. Keeping in mind the principles of natural justice, we deem it fit to grant another opportunity of hearing to the assessee. Accordingly, the impugned order is set aside and the matter is restored back to the file of Ld. AO for de-novo assessment with a direction to the assessee to plead and prove its case forthwith. 3. The appeal stands allowed for statistical purposes. Order pronounced on 03rd August, 2026

-Sd- -Sd- (LALIET KUMAR) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER AS Dated: 03-08-2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

ASSISTANT REGISTRAR

ITAT CHANDIGARH

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