THE PATRAN B R CHBS LIMITED DHANDIAL ROAD NEAR POST OFFICE, PATRAN S.O PATRAN PATIALA,PUNJAB vs. THE ASSESSMENT UNITS NFAC DELHI JAO INCOME TAX OFFICER WARD SAMANA AT PATIALA, PUNJAB
1
IN THE INCOME TAX APPELLATE TRIBUNAL
“B” BENCH CHANDIGARH.
BEFORE HON’BLE SHRI LALIET KUMAR, JM
AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM
आयकरअपील सं. / ITA No. 1037/CHANDI/2024 (िनधाŊरणवषŊ / Assessment Year: 2015-16) & 2. आयकरअपील सं. / ITA No. 1038/CHANDI/2024 (िनधाŊरणवषŊ / Assessment Year: 2019-20) The Patran B R CHBS Limited Dhandial Road near Post Office Patran S.O. Patran Patiala-147105 बनाम/ Vs. ITO Ward Samana Aaykar Bhawan, Leela Bhawan Mall Road, Patiala-147001 ̾थायीलेखासं./जीआइआरसं./PAN/GIR No. AAEAT-3959-L (अपीलाथŎ/Appellant) : (ŮȑथŎ / Respondent)
अपीलाथŎकीओरसे/Appellant by : Shri Sudhir Sehgal (Advocate ) – Ld. AR
ŮȑथŎकीओरसे/Respondent by :
Dr. Ranjit Kaur (Addl. CIT) - Ld. Sr. DR
सुनवाईकीतारीख/Date of Hearing
:
20-05-2025
घोषणाकीतारीख /Date of Pronouncement
:
21-05-2025. आदेश / O R D E R
Per Bench
1. Aforesaid appeals have identical facts. First, we take up appeal for Assessment Year (AY) 2015-16 which arises out of an order of learned
Commissioner of Income Tax (Appeals), National Faceless Appeal
Centre (NFAC), Delhi [CIT(A)] dated 17-08-2024 in the matter of an assessment framed by Ld. AO u/s 144 r.w.s. 147 of the Act on 29-12-
2023. The assessment has been framed on best judgment basis wherein Ld. AO made addition of unexplained money u/s 69A for Rs.614.79 Lacs. The Ld. CIT(A) did not admit the appeal for want of 2
condonation of delay of 65 days. Similar are the facts in AY 2019-20. Aggrieved, the assessee is in further appeal before us in both the years.
The Ld. AR has prayed for another opportunity of hearing before lower authorities which has been opposed by Ld. Sr. DR.
2. Keeping in mind the principles of natural justice and considering the possibility of communication gaps during faceless regime, we deem it fit to afford another opportunity of hearing to the assessee to substantiate its case before Ld. CIT(A). However, The same shall come at a cost of Rs.10,000/- for both the appeals which shall be deposited by the assessee within 30 days from the date of receipt of this order to ‘Prime Minister’s National Relief Fund’. The proof of the same shall be furnished by the assessee to Ld. CIT(A) who shall proceed for de novo adjudication on merits without raising the issue of delay. The assessee is directed to substantiate its case forthwith.
3. Both the appeals stand allowed for statistical purposes.
Order pronounced on 21-05-2025. (LALIET KUMAR) (MANOJ KUMAR AGGARWAL)
JUDICIAL MEMBER लेखा सद˟ /ACCOUNTANT MEMBER
Dated: 21-05-2025. आदेश की Ůितिलिप अŤेिषत / Copy of the Order forwarded to :
1. अपीलाथŎ/Appellant
2. ŮȑथŎ/Respondent
3. आयकरआयुƅ/CIT
4. िवभागीयŮितिनिध/DR
5. गाडŊफाईल/GF