RAAVI INTERNATIONAL VENTURES LLP,NEARELA, NEW DELHI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-15, DELHI, JHANDEWALAN, NEW DELHI
What did the Tribunal hold?
The Tribunal acknowledged the possibility of communication gaps, especially with the new virtual hearing mechanism. Therefore, it was deemed appropriate to restore the appeals to the CIT(A) for fresh adjudication.
What were the facts?
The assessee's appeals for AY 2020-21 and 2021-22 were against CIT(A) orders. The assessee claimed communication gaps prevented them from presenting their case effectively in the lower appellate proceedings.
What were the issues?
Whether the assessee was prevented from adequately presenting their case before the CIT(A) due to communication gaps, warranting a remand.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: ‘H’ NEW DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI SANJAY AWASTHI
IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘H’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER ITA Nos.1032 & 1033/Del/2026 Assessment Years: 2020-21 & 2021-22 M/s. Raavi International Vs. DCIT, Ventures LLP, Central Circle-15, Kh No. 17/18 (1 to 100), Tajpur Delhi Road, Opposite Kusum Farm Singhola, Narela, New Delhi - 110040 PAN: ABBFR0091A (Appellant) (Respondent) Assessee by Sh. Baldev Raj, CA Ms. Sanju Kumari, Adv. Department by Sh. Bhopal Singh, CIT(DR) Date of hearing 29.06.2026 Date of pronouncement 29.06.2026 ORDER PER SATBEER SINGH GODARA, JM These assessee’s twin appeals ITA Nos.1032 & 1033/Del/2026 for assessment years 2020-21 & 2021-22, arise against the Commissioner of Income Tax (Appeals) [in short, the “CIT(A)”], Delhi’s-26 orders, both dated 28.11.2025, having DINs and orders no. ITBA/APL/S/250/2025-26/1083103366(1) &
ITA Nos.1032 & 1033/Del/2026
1083102613, involving proceedings under section 147 r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. 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). The Revenue vehemently supports the learned lower authority’s action making the addition(s) herein on merits. 3. 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 both the appeals back to the CIT(A) for their afresh appropriate adjudication, within three effective opportunities of hearing at the appellant’s risk and responsibility, in consequential proceedings. Ordered accordingly.
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ITA Nos.1032 & 1033/Del/2026
These assessee’s twin appeals ITA Nos.1032 & 1033/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 29th June, 2026 Sd/- Sd/- (SANJAY AWASTHI) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 6th 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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