THE PONDICHERRY VETERINARY COLLEGE SOCIETY,PUDUCHERRY vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1, PUDUCHERRY

Aforesaid appeal by assessee for Assessment Year (AY) 2015-16 arises out of an order of learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] dated 21-08- 2024 in the matter of an assessment 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 20-03-2023. The grievance of the assessee is two-fold i.e., Addition of Rs.109.41 Lacs u/s. 69A and another addition of Rs.55.00 Lacs u/s 69. 2

Upon perusal of para-6.1 of impugned order, it could be seen that the assessee has failed to attend first appellate proceedings and accordingly, the assessment has been confirmed. Aggrieved, the assessee is in further appeal before us. The Ld. AR has prayed for another opportunity before lower authorities which has been opposed by revenue. 3. It is evident that the assessee has failed to substantiate its stand during first appeal. However, keeping in mind the principles of natural justice, we accept the prayer of Ld. AR. Accordingly, the impugned order is set aside and the appeal is restored back to the file of Ld. CIT(A) for de novo adjudication with a direction to the assessee to substantiate its case. 4. The appeal stand allowed for statistical purposes. Order pronounced on 2nd January, 2025 (S. S. VISWANETHRA RAVI) (MANOJ KUMAR AGGARWAL) ाियक सद! / JUDICIAL MEMBER लेखा सद! / ACCOUNTANT MEMBER