PAJETHILANI LARGE SCALE MULTIPURPOSE COOPERATIVE SOCIETY LIMITED,KALSI vs. INCOME TAX OFFICER, WARD 1(1)(2), INCOME TAX OFFICE, DEHRADUN, SUBHASH ROAD DEHRADUN

PDF · subscribers
ITA 198/DDN/2026Status: DisposedITAT Dehradun24 August 2026AY 2020-213 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal condoned the delay and restored the appeal to the CIT(A) for fresh adjudication. This was done to ensure justice, acknowledging potential communication issues with the virtual hearing mechanism.

What were the facts?

The assessee's appeal for AY 2020-21 was filed late due to communication gaps. The assessee could not present all facts in the lower appellate proceedings.

What were the issues?

Whether the assessee was prevented from presenting their case effectively due to communication gaps in the virtual hearing process, 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: “SMC” NEW DELHI

Before: SHRI SATBEER SINGH GODARA&

For Respondent: DR (VC)
Hearing: 18.08.2026Pronounced: 24.08.2026

This assessee’s appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1082948912(1), dated 24.11.2025, involving proceedings under section 147 of the Income-tax Act, 1961; hereinafter referred to as ‘the Act’.

ITA No. 198/DDN/2026

Heard both the parties. Case file perused.

2.

Delay of 67 days in filing of the assessee’s instant appeal is condoned in larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).

3.

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 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) for his afresh appropriate adjudication, within three 2 | P a g e

ITA No. 198/DDN/2026

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 24.08.2026.

Sd/- Sd/- (AMITABH SHUKLA) (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

3 | P a g e

More judgments on Section 147

All 49,210 judgments and leading authorities on Section 147 →

Recent GST High Court judgments

Search GST case law →