What did the Tribunal hold?

The Tribunal acknowledged the possibility of communication gaps, especially with the new virtual hearing mechanism. Therefore, it was deemed appropriate to restore the appeal to the CIT(A) for fresh adjudication.

The assessee's appeal for AY 2021-22 was against the CIT(A)'s order. The assessee claimed that due to communication gaps, they could not present all relevant facts in the lower appellate proceedings.

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.

Sadhna Rani vs DCIT | s.143(3) | ITAT Delhi 2026

Income Tax Appellate Tribunal, DELHI BENCH: ‘E’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI NAVEEN CHANDRA

For Appellant: Adv. Ms. Uma Upadhyay, CA

For Respondent: Ms. Amisha S Gupt., CIT(DR)

Hearing: 20.05.2026Pronounced: 20.05.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.7951/Del/2025 Assessment Year: 2021-22 Sadhna Rani, Vs. DCIT, B-26, Swasthya Vihar, Central Circle-31, Nirman Vihar, East Delhi, New Delhi Delhi PAN: ABHPA9244J (Appellant) (Respondent) Assessee by Sh. Ved Jain, Adv. Ms. Uma Upadhyay, CA Department by Ms. Amisha S Gupt., CIT(DR) Date of hearing 20.05.2026 Date of pronouncement 20.05.2026 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2021-22, arises against the Commissioner of Income Tax (Appeals)-30 [in short, the “CIT(A)”], New Delhi’s order dated 31.10.2025 having DIN and order no. ITBA/APL/M/250/2025-26/1082210373(1), involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

ITA No.7951/Del/2025

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 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) 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 May, 2026

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ITA No.7951/Del/2025

Sd/- Sd/- (NAVEEN CHANDRA) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 21st May, 2026. RK/- Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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SADHNA RANI,DELHI vs. DCIT, CENTRAL CIRCLE-31, NEW DELHI

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Which sections of the Income-tax Act were involved?

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