SUCHITA NARULA,HARYANA vs. ITO. WARD-1(4), FARIDABAD, HARYANA
What did the Tribunal hold?
The Tribunal held that since the CIT(A)/NFAC had proceeded ex-parte against the assessee, there was a possibility of communication gaps between the taxpayer and the counsel, especially with the introduction of the faceless hearing system. In the larger interest of justice, the Tribunal decided to restore the assessee's appeal back to the CIT(A)/NFAC for fresh adjudication. The assessee was granted three effective opportunities to plead and prove its case at its own risk and responsibility. The appeal was allowed for statistical purposes. No specific amount in dispute was recorded. The Tribunal did not decide on the merits of the additions or disallowances.
What were the facts?
The assessee, Suchita Narula, filed an appeal for Assessment Year 2020-21 against an order passed by the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi. The impugned order, dated 14.05.2026, was passed under Section 147 read with Sections 144 and 144B of the Income Tax Act, 1961. The CIT(A)/NFAC had proceeded ex-parte against the assessee, affirming the Assessing Officer's disallowances and additions. The case was called twice, and no one appeared on behalf of the assessee, leading to the proceedings being ex-parte.
What were the issues?
1. Whether the Tribunal should restore the appeal to the CIT(A)/NFAC for fresh adjudication, considering the possibility of communication gaps due to the faceless assessment system, when the CIT(A)/NFAC had proceeded ex-parte against the assessee? Assessee's Contention: Not recorded as the assessee was proceeded ex-parte. The appeal was filed by the assessee. Revenue's Contention: The learned Departmental Representative argued that the assessee had not filed any explanation or evidence supporting its case, and therefore, the appeal deserves to be dismissed. The revenue supported the findings of the CIT(A).
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI
Before: SHRI SATBEER SINGH GODARA
आयकर अपीलीय अिधकरण, िद�ी पीठ�, नई िद�ी INCOME TAX APPELLATE TRIBUNAL, DELHI BENCHES, NEW DELHI BENCH: SMC BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA 7189/DEL/2026 (िनधा�रण वष�/Assessment Year: 2020-21) SUCHITA NARULA, HARYANA ITO WARD-1(4), HOUSE NO.669, SECTOR 15A, Vs. FARIDABAD FARIDABAD, HARYANA – 121 002 अपीलाथ� / Appellant ��थ� / Respondent
Permanent Account Number of Assessee: ACOPN 2476 P
अपीलाथ� �ारा/Appellant represented by: -None- ��थ� �ारा/Respondent represented by: Sh. Manoj Kumar, Sr. DR सुनवाई की तारीख / Date of conclusion of hearing: 03-Sep-2026 घोषणा की तारीख / Date of pronouncement: 03-Sep-2026 आदेश / ORDER PER SATBEER SINGH GODARA, JUDICIAL MEMBER: This assessee’s appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)/ National Faceless Appeal Centre (NFAC), Delhi [in short, the “CIT(A)/NFAC”], order no. and DIN: ITBA/NFAC/S/250/2026-27/1089007442(1), dated 14.05.2026 involving proceedings u/s 147 r.w.s 144 read with section 144B of the Income Tax Act 1961 (hereinafter referred to as ‘the Act’).
Case called twice. None appears at the assessee’s behest. She is accordingly proceeded ex-parte.
ITA 7189/DEL/2026 SUCHITA NARULA, HARYANA
It emerges at the outset during the course of hearing that the learned CIT(A)/NFAC’s in its lower appellate order has proceeded ex-parte against the assessee thereby affirming the Assessing Officer’s action making the corresponding disallowances/additions herein.
Learned DR vehemently argues during the course of hearing in support of CIT(A)’s finding that the assessee had not filed any explanation or evidence supporting it’s case and therefore, his instant appeal deserves to be dismissed.
I have given my thoughtful consideration to the foregoing rival stands and are of the considered view that since the CIT(A) has proceeded ex-parte against the assessee, possibility of some communication gaps between the taxpayer and the arguing counsel involving the newly introduced system of faceless hearings, could not be altogether ruled out.
Faced with this situation, I deem it appropriate, in the larger interest of justice, to restore the assessee’s instant appeal back to the CIT(A)/NFAC for his afresh appropriate adjudication, within three effective opportunities subject to a rider that the taxpayer shall plead and prove the case at his own risk and responsibility, in consequential proceedings. Ordered accordingly.
This assessee’s appeal is allowed for statistical purposes. Order pronounced in the open court on 03.09.2026.
Sd/- SATBEER SINGH GODARA JUDICIAL MEMBER Delhi Dated: 07.10.2026 Priti Yadav, Sr. PS*
ITA 7189/DEL/2026 SUCHITA NARULA, HARYANA
Copy to: SUCHITA NARULA, HARYANA 1 HOUSE NO.669, SECTOR 15A, FARIDABAD, HARYANA – 121 002 ITO 2 WARD-1(4), FARIDABAD 3 THE PCIT / CIT, 4 THE D.R., ITAT, DELHI BENCH 5 GUARD FILE
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