SANJIV NARANG,NEW DELHI vs. ASSESSING OFFICER , NEW 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 No.- 1571/Del/2026 [Assessment Year: 2017-18] Sanjiv Narang, Assessing Officer, N-239, Greater Kailash -1, Ward 52(4), New Delhi-110048. Vs New Delhi- 110002. PAN- AACPN5860D Assessee Revenue Assessee by Ms. Gunjan Jain, CA Revenue by Sh. Manoj Kumar, Sr. DR Date of Hearing 22.07.2026 Date of Pronouncement 22.07.2026 ORDER Per Renu Jauhri, Accountant Member:

This appeal by the assessee is directed against the order dated 29.08.2025 of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘Ld. CIT(A)] arising out of the Assessment Order dated 30.12.2019 passed under section 144 r.w.s. 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the Ward 52(4), Delhi, (hereinafter referred to as the ‘AO’) pertaining to Assessment Year (A.Y.) 2017-18.

ITA No.- 1571/Del/2026 Sanjiv Narang 2. The assessee has raised the following grounds of appeal:

“ 1. That under the facts and circumstances of the case, the orders dated 29.08.2025 under section 250 of the Act passed by the Ld. First appellant authority is grossly injudicious, unwarranted and bad at law. 2. The Ld. A.O. have erred in passing the impugned order and notice under section 143(2) of the Act on the assessee without having any valid jurisdiction on the assessee, which makes the entire assessment void ab initio and bad at law. 3. That under the facts and circumstances of the case the learned assessing officer grossly erred in law without issuing a mandatory show cause notice thereby denying the assessee an opportunity of being heard prior to passing the order under section 144 read with section143(3) of the Act which clearly constitutes a procedural error as prescribed under the Income Tax Act,1961 and violation of principle of natural justice. 4. The ld. A.O. and appellate first authority has refrained the assessee from an opportunity of being heard which is against the principle of natural justice. 5. That under the facts and circumstances of the case, the Ld. First appellant authority has grossly erred in upholding the orders of the Ld. Assessing officer without application of mind and without understanding the relevant documents in the present case. 6. That under the facts and circumstances of the case, the first appellant authority has grossly erred in confirming the addition amounting to Rs. 20,25,000/- under section 69A of the Act treating the same as unexplained money which is grossly arbitrary, highly injudicious and bad at law. 7. That under the facts and circumstances of the case, the first appellant authority has grossly erred in confirming the addition amounting to Rs. 42,61,879/- on ad-hoc basis by applying the profit margin ratio of earlier year on the total bank credits of the assessee which is highly injudicious and bad at law. 8. That under the facts and circumstances of the case, the first appellant authority has grossly erred in confirming the addition amounting to Rs. 62,86,879/- is hypothetical, arbitrary, and in imaginary manner. 9. That under the facts and circumstances of the case the assessment order passed by the learned assessing officer making an addition of Rs. 62,86,879/- is non-self- explanatory which is unjustified, arbitrary and bad at law. 10.The appellant prays for leave to add, amend, alter or withdraw of any grounds of appeal.”

ITA No.- 1571/Del/2026 Sanjiv Narang 3. Brief facts are that the assessee filed his return for A.Y. 2017-18 declaring income of Rs. 2,98,900/-. The case was selected for scrutiny and assessment was completed at an income of Rs. 65,85,779/- after making addition of Rs. 20,25,000/- on account of unexplained cash credits and Rs. 42,61,879/- u/s 143(3) r.w.s. 144 dated 30.12.2019. 3.1 Aggrieved, the assessee filed an appeal before the CIT(A). As no compliance was made to the multiple notices issued during appellate proceedings, the CIT(A) dismissed the appeal vide order dated 29.08.2025. Further aggrieved, the assessee is in appeal before the Tribunal. 4. We have heard the rival submissions and perused the material available on record. In the interest of justice, we deem it appropriate to restore the matter to the CIT(A) for fresh adjudication on merits after giving due opportunity to the assessee. The assessee is also directed to be vigilant and make requisite compliance before the CIT(A). 5. In the result, appeal of the assessee is allowed for statistical purposes. Order pronounced in the open court on 22.07.2026

Sd/- Sd/- [SATBEER SINGH GODARA] [RENU JAUHRI] JUDICIAL MEMBER ACCOUNTANT MEMBER Dated- 24.07.2026. Pooja, Sr. PS.

ITA No.- 1571/Del/2026 Sanjiv Narang Copy forwarded to: 1. Assessee 2. Respondent 3. CIT 4. CIT(A) 5. DR

Asst. Registrar, ITAT, New Delhi,