FROZEN IRON AND STEEL PRIVATE LIMITED,MAHARASHTRA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-25, NEW DELHI

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ITA 3554/DEL/2026Status: DisposedITAT Delhi24 August 2026AY 2016-173 pages
AI SummaryRemanded

What did the Tribunal hold?

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

What were the facts?

The assessee's appeal for AY 2016-17 was filed against the CIT(A)'s order. The assessee contended that due to communication gaps, they could not present all relevant facts before the lower appellate authority.

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.

Which sections of the Income-tax Act were involved?

Section 147

AI-generated summary — verify with the full judgment below

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

Before: SHRI SATBEER SINGH GODARA & SHRI NAVEEN CHANDRA

For Appellant: CA &
Hearing: 13.08.2026Pronounced: 13.08.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “A” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 3554/Del/2026 Assessment Year: 2016-17 Frozen Iron and Steel Private Vs. Assistant Commissioner of Limited, Income Tax, B-426, 4th Floor, NBC Central Circle-25, Complex, Plot No. 43, Jhandewalan Extension, Sector-11, CBD Belapur, New Delhi- 55 Navi Mumbai, Thane- 400614, Maharashtra PAN: AABCF4439Q (Appellant) (Respondent) Assessee by Sh. Ashwani Kumar, CA & Sh. Ankur Agarwal, CA Department by Sh. Zafarul Haque Tanweer, CIT DR

Date of hearing 13.08.2026 Date of pronouncement 13.08.2026 ORDER

This assessee’s appeal for assessment year 2016-17, arises against the Commissioner of Income Tax (Appeals)-29 [in short, the “CIT(A)”], New Delhi’s order no. 11198/2015-16, dated 27.02.2026, involving proceedings under section 147 of the Income-tax Act, 1961; hereinafter referred to as ‘the Act’.

ITA No. 3554/Del/2026

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 matter may be restored back to the CIT(A). The Revenue vehemently supports the learned lower authorities’ 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 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.

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ITA No. 3554/Del/2026

5.

This assessee’s appeal is allowed for statistical purposes.

Order pronounced in the open court on 13.08.2026.

Sd/- Sd/- (NAVEEN CHANDRA) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER

Dated: 24.08.2026 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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