JAI SINGH GOEL,DELHI vs. DCIT CC-15, DELHI

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ITA 5842/DEL/2026Status: DisposedITAT Delhi09 July 2026AY 2022-233 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal acknowledged the possibility of communication gaps and restored the appeals to the CIT(A) for fresh adjudication. The assessee was granted three effective opportunities to be heard.

What were the facts?

The assessee's appeals for three assessment years were against the CIT(A)'s orders. The assessee claimed communication gaps prevented them from presenting all facts in the lower appellate proceedings.

What were the issues?

Whether the assessee was prevented from adequately pleading their case before the CIT(A) due to communication gaps, warranting a remand.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI

Before: SHRI SATBEER SINGH GODARA

For Appellant: Shri Baldev Raj, CA, Shri Maneesh Upneja, CA &, Ms. Sanju Kumari, Adv
Hearing: 09.07.2026Pronounced: 09.07.2026

These Assessee’s three appeals in ITA Nos.5840 to 5842/Del/2026 for assessment years 2018-19, 2019-20 and 2022-23, arise against the Commissioner of Income Tax (Appeals), [in short, the “CIT(A)”], Delhi-26’s orders all dated

ITA No.- 5840 to 5842/Del/2026 Jai Singh Goel 13.04.2026 having DIN & order No.: ITBA/APL/S/250/2026-27/1088419747(1), 1088419480(1) & 1088419209(1), involving proceedings under sections 147 r.w.s. 143(3) of the Income-tax Act, 1961; hereinafter referred to as, ‘the Act’; respectively.

2.

Heard both the parties. Cases file perused.

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 matter may be restored back to the CIT(A). 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 could not be altogether ruled out. It is therefore deemed appropriate in the larger interest of justice to restore the assessee’s instant appeals back to the CIT(A) for his afresh appropriate adjudication, within three effective opportunities of hearing at the appellant’s risk and responsibility, in consequential proceedings. Ordered accordingly.

ITA No.- 5840 to 5842/Del/2026 Jai Singh Goel 5. These assessee’s three appeals ITA Nos. 5840 to 5842/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 09th July, 2026

Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER

Dated: 15th July, 2026. Pooja. Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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