JOINT COMMISSIONER OF INCOME TAX (IN SITU), CL-I, , LUDHIANA vs. MAHESH GOYAL, LUDHIANA

Aforesaid appeal by revenue for Assessment Year (AY) 2014-15 arises out of an order of learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] dated 04-12- 2024 in the matter of an assessment framed by Ld. Assessing Officer [AO] on best judgment basis u/s. 147 r.w.s. 144B of the Act on 31-03- 2022. The Ld. AO assessed the income of the assessee by making addition of Rs.230.60 Lacs. The assessee failed to make any effective representation during the course of assessment proceedings. The Ld. CIT(A), considering assessee’s submission and evidences, exercised remand power in terms of proviso to Sec.251(1)(a) and directed Ld. AO to make fresh assessment. So aggrieved, the revenue is in further appeal before us. 2. We are of the considered opinion that the assessment was framed on best judgment basis and the assessee filed fresh submissions / evidences during first appeal. Since the same would have material bearing on the assessment of the assessee, Ld. AO was directed to make fresh assessment. In our opinion, on the facts of the case, the power of remand has validly been exercised by Ld. CIT(A) and we find no infirmity in the same. 3. The appeal stands dismissed. Order Pronounced on 18-08-2025. (LALIET KUMAR) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER