RAMAN SEHGAL,CHANDIGARH vs. ITO WARD 2(1), CHANDIGARH, CHANDIGARH

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, CHANDIGARH HYBRID HEARING HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकर अपील सं./ ITA No.1284/CHANDI/2026 (िनधा�रण वष� / Assessment Year: 2018-19) Shri Raman Sehgal ITO Ward 2(1) बनाम/ Vs. 5029/2, Modern Housing Complex Aaykar Bhawan, Sector – 17 Manimajra, Chandigarh – 160101 Chandigarh – 160017 �ायीलेखासं./जीआइआरसं./PAN/GIR No. ANDPS-3197-G (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Sh. Parikshit Aggarwal (CA) – Ld. AR ��थ�कीओरसे/Respondent by : Dr. Ranjit Kaur (Addl. CIT) - Sr. DR(Virtual) सुनवाईकीतारीख/Date of Hearing : 14-07-2026 घोषणाकीतारीख /Date of Pronouncement 20-07-2026 : आदेश / O R D E R 1. Aforesaid appeal by assessee for Assessment Year (AY) 2018- 19 arises out of an order of learned Commissioner of Income Tax (Appeals). NFAC [CIT(A)] dated 27.03.2026 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 147 r.w.s. 144B of the Act on 24.03.2023. In the assessment order, Ld. AO disallowed purchases of Rs.18.52 Lacs for want of substantive evidences from the assessee. The said purchases were made by the assessee from M/s RCI industries & Technologies Ltd. to whom notice was sent u/s 133(6) which remained non-complied with by that entity. The assessee could not furnish bank account of that party and other evidence to

demonstrate actual movement of goods. The position remained the same during first appeal and accordingly, the assessment was confirmed against which the assessee is in further appeal before us. The only prayer of Ld. AR is another opportunity of hearing to the assessee to substantiate its case which has been opposed by Ld. Sr. DR. 2. It is clear that the onus to establish the genuineness of impugned purchases with cogent evidences could not be discharged by the assessee during proceedings before lower authorities. Keeping in mind the principles of natural justice, I accept the prayer of Ld. AR and accordingly, restore the matter back to Ld. CIT(A) with a direction to the assessee to plead and prove its case forthwith. No other ground has been urged in the appeal. 3. The appeal stand allowed for statistical purposes. Order pronounced on 20th July, 2026. -Sd- (MANOJ KUMAR AGGARWAL) ACCOUNTANT MEMBER AS Dated: 20/07/2026 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