DEEPAK KHULLAR,DELHI vs. ITO WARD - 34 (1), DELHI

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘A’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SMT. RENU JAUHRI, ACCOUNTANT MEMBER ITA Nos.3304 & 3305/Del/2026 Assessment Year: 2020-21 Deepak Khullar, Vs. Income Tax Officer, AG-137, Shalimar Bagh, Ward-34(1), New Delhi – 110 088 New Delhi PAN: AGCPK2795A (Appellant) (Respondent) Assessee by Sh. V. Rajaj Kumar, Adv. Department by Sh. Manoj Kumar, Sr. DR Date of hearing 21.07.2026 Date of pronouncement 21.07.2026 ORDER PER SATBEER SINGH GODARA, JM These assessee’s twin appeals ITA Nos.3304 & 3305/Del/2026 for assessment year 2020-21, arise against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s orders, both dated 30.12.2025, having DINs and orders no. ITBA/NFAC/S/250/2025-26/1084202449(1) & 1084202518 involving proceedings under section 147 r.w.s. 144 and 272A(2)(d)

ITA Nos.3304 & 3305/Del/2026

of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’); Respectively. Heard both the parties. Case file perused. 2 For the reasons stated in the assessee’s condonation averments, delay of 27 days in filing of both the instant appeals is condoned in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC). 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, the matters may be restored back to the CIT(A)/NFAC. The Revenue vehemently supports the learned lower authority’s action making the addition(s) herein on merits. 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. It is therefore deemed appropriate in the larger interest of justice to restore the assessee’s instant “quantum” appeal

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ITA Nos.3304 & 3305/Del/2026

ITA No.3304/Del/2026 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. The assessee’s “quantum” appeal ITA No.3304/Del/2026 is allowed for statistical purposes. Same order to follow in the assessee’s “penalty” appeal ITA No.3305/Del/2026 being consequential in nature. 6. These assessee’s twin appeals ITA Nos.3304 & 3305/Del/2026 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 21st July, 2026 Sd/- Sd/- (RENU JAUHRI) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 23rd July, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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