PAUL NADAR JACAB THOMAS,TIRUPPUR vs. ITO, WARD-2(4), TIRUPPUR

Aforesaid appeals by assessee for Assessment Years (AY) 2013- 14 & 2014-15 arise out of separate orders of learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] both dated 13-08-2024 in the matter of separate assessments framed by Ld. Assessing Officer [AO] on best judgment basis u/s. 147 r.w.s. 144 r.w.s. 144B of the Act on 30-03-2022. The grievance of the assessee is confirmation of addition of cash deposits of Rs.145.84 Lacs in AY 2013-14 and addition of Rs.166.43 Lacs for AY 2014-15 on account of unexplained investment u/s.69A of the Act. The assessments have been made on best judgment basis. Though the assessee preferred further appeals, it failed to make any representation therein also. Accordingly, the assessments were confirmed. Aggrieved, the assessee is in further appeals before us. The Ld. AR has prayed for another opportunity of hearing which has been opposed by Ld. Sr. DR.

Though the assessee has remained negligent in substantiating its case during lower authorities, however, keeping in mind the principle of natural justice, we deem it fit to grant another opportunity to the assessee to substantiate its case before Ld. AO. Accordingly, the impugned orders are set aside for both the years and the assessments are restored back to the file of Ld. AO for de novo assessments with a direction to the assessee to substantiate its case forthwith.

Both the appeals stand allowed for statistical purposes. Order pronounced on 2nd January, 2025 Sd/- Sd/- (S. S. VISWANETHRA RAVI) (MANOJ KUMAR AGGARWAL) �ाियक सद! / JUDICIAL MEMBER लेखा सद! / ACCOUNTANT MEMBER चे4ई Chennai; िदनांक Dated :02-01-2025 DS आदेशकीSितिलिपअ&ेिषत/Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. � थ�/Respondent 3. आयकरआयु=/CIT Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाडBफाईल/GF