DELHIVERY FREIGHT SERVICES PRIVATE LIMITED,DELHI, 110037 vs. INCOME TAX OFFICER, WARD 7(1), DELHI, DELHI

आदेश / ORDER

PER SUDHIR KUMAR, JUDICIAL MEMBER:

This appeal is filed by the Assessee against the order of National Faceless Appeal Centre (NFAC)/Commissioner of Income Tax (Appeals) (hereinafter referred as CIT(A) dated 14-10-2025 for the Assessment Year 2021-22.

genuineness of transaction and business nature of the payables were explained by the assessee. It was further submitted by the Ld. AR that Ld. CIT(A) failed to appreciate that the assessee was not furnished complete copies of the notices u/s. 133(6) as well as the accounts/ ledgers/ information of the vendors, and hence, the addition made on such basis is vitiated in law. However, the Learned authorized representative for Revenue stated that departmental authorities have passed reasoned orders, after providing adequate opportunities to the assessee. 3. We have heard the rival contentions and perused the material available on record. It is an

admitted fact that it was the plea of the assessee before the Ld. CIT(A) that it was not given

copies of all account statement or confirmations obtained by the AO. However, Ld. CIT(A)

observed that AO provided copies of replies received from Orion Supply Chain (P) Ltd. and

Triumula Transport Co. on 7.12.2022, 8.12.2022 and 9.12.2022 and asked the assessee to

reconcile. However, assessee had sought time but could not furnish reconciliations even till

the completion of assessment. Ld. CIT(A) noted that plea of insufficient time cannot be

accepted at the appellate stage when multiple opportunities had already been given. Ld.

CIT(A) further observed that the assessee’s accounting policy on revenue recognition and

matching concept, and the peculiarities of its AXLE application, may explain part of the

difference; however, without corroborative evidence from the counter parties, the onus under

sections 68 and 69C remains undischarged. In view of above observations, we note that in

the absence of proper corroborative evidences, the Ld. CIT(A) himself noted that the onus

under sections 68 and 69C remains undischarged, which in our considered opinion, needs to

be discharged by the Assessee to enable the lower authorities to adjudicate upon the issue in

dispute in a proper way. Thus, we deem fit and proper to remit back the issues in dispute to

the file of the AO for fresh consideration, after giving adequate opportunity of being heard to

the assessee. We hold and direct accordingly. However, assessee is directed through his

Authorised Representative to substantiate its case before the AO by furnishing all the requisite

and proper corroborate evidences and fully cooperate with the AO during the proceedings.

The grounds raised by the assessee are accordingly allowed for statistical purposes.

(MANISH AGARWAL) (SUDHIR KUMAR) ACCOUNTANT MEMBER (JUDICIAL MEMBER) SR BHATTANGAR

Date: 22.05.2026