What did the Tribunal hold?

The Tribunal found that communication gaps could not be ruled out and, in the interest of justice, restored the appeal back to the CIT(A) for fresh adjudication. The CIT(A) was directed to provide three effective opportunities for hearing.

The assessee's appeal for AY 2022-23 was filed against the CIT(A)'s order. The assessee contended that due to communication gaps, they could not present all relevant facts in the lower appellate proceedings.

What were the issues?

Whether the assessee was prevented from presenting their case effectively before the CIT(A) due to communication gaps, warranting a remand for fresh adjudication.

R N Brothers, Muzaffarnagar vs DCIT | ITAT Delhi 2026

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

Before: SHRI SATBEER SINGH GODARA

For Appellant: Adv. (VC)

Hearing: 02.06.2026Pronounced: 02.06.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No. 3804/Del/2026 Assessment Year: 2022-23 M/s R N Brothers, Vs. Deputy Commissioner of 35, Vehlana Chowk, Income Tax Meerut Road, Central Circle-15 Muzaffarnagar- 251 003 Jhandewalan Extension, Uttar Pradesh New Delhi- 110055 PAN: AAHFR1136M (Appellant) (Respondent) Assessee by Sh. Ankit Gupta, Adv. (VC) Department by Sh. Manoj Kumar, Sr. DR

Date of hearing 02.06.2026 Date of pronouncement 02.06.2026 ORDER This assessee’s appeal for assessment year 2022-23, arises against the Commissioner of Income Tax (Appeals)[in short, the “CIT(A)”],Delhi-26’s order dated 06.02.2026, passed in DIN & order no. ITBA/APL/S/250/2025-26/1085699219(1), involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties. Case file perused.

Learned counsel submits that on account of communication gaps at various levels, the assessee could not appear to plead and

ITA No. 3804/Del/2026 prove all the relevant facts in the lower appellate proceedings and therefore, larger interest of justice would be met, in case, the matter may be restored back to the Assessing Officer. The Revenue vehemently support the learned lower authorities action making addition(s) herein on merits.

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 appeal 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. 5. This assessee’s appeal is allowed for statistical purposes.

Order pronounced in the open court on 2nd June, 2026. Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 29.06.2026 Pooja Mittal/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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R N BROTHERS,MUZAFFARNAGAR vs. DEPUTY COMMISSIONER OF INCOME TAX, CC-15, DELHI

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