PIGEON EXPORTS INTERNATIONAL P LTD,NEW DELHI vs. ACIT, CIRCLE- 19(1), DELHI

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)/NFAC. 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 instant appeal back to the CIT(A)/NFAC for his afresh appropriate adjudication, within three effective opportunities of hearing at the appellant’s risk and responsibility, in consequential proceedings. Ordered accordingly. 4. This assessee’s appeal is allowed for statistical purposes. Order pronounced in the open court on 20th April, 2026 Sd/- Sd/- (NAVEEN CHANDRA) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 28th April, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 2 | P a g e

DR Asst. Registrar, ITAT, New Delhi