RACHANA SINGH, CHANDIGARH,CHANDIGARH vs. DEPUTY COMMISSIONER OF INCOME TAX CC-2,, CHANDIGARH
What did the Tribunal hold?
The Tribunal restored the appeal to the CIT(A) for fresh adjudication, emphasizing the principles of natural justice. The assessee was directed to plead and prove its case, with all issues kept open.
What were the facts?
The assessee's appeal for AY 2013-14 was restored to the CIT(A) for fresh adjudication. The AO had made additions on account of unexplained jewellery, and the assessee claimed to be in a position to explain the sources.
What were the issues?
Whether the assessee should be granted another opportunity of hearing before the CIT(A) to explain the sources of jewellery.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH
Before: HON’BLE SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM
IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH PHYSICAL HEARING BEFORE HON’BLE SHRI LALIET KUMAR, JM AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकर अपील सं. / ITA No.1660/CHANDI/2025 (िनधा�रण वष� / Assessment Year: 2013-14) M/s Rachana Singh DCIT-CC-2 #288, Sector – 10-A Ground Floor, C.R. Building बनाम/ Vs. Chandigarh - 160011 Sector – 17-E, Himalaya Marg, Chandigarh �ायीलेखासं./जीआइआरसं./PAN/GIR No. ABSPR-0544-F (अपीलाथ�/Appellant) (��थ� / Respondent) : अपीलाथ�कीओरसे/ Appellant by : Sh. Sudhir Sehgal (Advocate) – Ld. AR ��थ�कीओरसे/Respondent by : Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 18-05-2026 घोषणाकीतारीख /Date of Pronouncement 18-05-2026 : आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2013-14 arises out of an order of learned Commissioner of Income Tax (Appeals)-3, Gurgaon [CIT(A)] dated 23.10.2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 153B(1)(b) r.w.s. 143(3) r.w.s. 254 of the Act on 30.09.2019. The only prayer of Ld. AR is another opportunity of hearing before Ld. CIT(A) which has been opposed by Ld. Sr. DR.
In the assessment order, Ld. AO made substantive as well as protective additions for Rs.10.31 Lacs each on account of unexplained jewellery. The matter reached up-to Tribunal vide ITA No.895/Chd/2018 dated 20.11.2018 wherein the matter stood restored back to Ld. AO with certain directions. The Ld. AO again made addition of Rs.15.31 Lacs. Though the assessee preferred further appeal, it remained non-responsive therein. Consequently, the assessment was confirmed ex-parte qua the assessee. The Ld. AR has stated that the assessee is in a position to explain the sources of jewellery. 3. Keeping in mind the principles of natural justice, we accept the prayer of Ld. AR. Accordingly, the appeal stand restored back to Ld. CIT(A) for fresh adjudication with a direction to the assessee to plead and prove its case. All the issues are kept open. 4. The appeal stand allowed for statistical purposes. Order pronounced on 18th May, 2026.
-Sd- -Sd- (LALIET KUMAR) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER AS Dated:18.05.2026 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
More judgments on Section 153B(1)(b)
- Praveen Kumar Saini, Jhunjhunu vs Income Tax Officer Ward-1, JhunjhunuITA 325/JPR/2026[2014-15]Status: Disposed28 Sept 2026AY 2014-15
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- Asst. Commissioner of Income Tax, Chennai vs True Friend Management Support Services Pvt…ITA 3643/CHNY/2025[2020-21]Status: Disposed29 May 2026AY 2020-21
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