OLIVIA TRADEX PRIVATE LIMITED,DELHI vs. ASSISTANT COMMISSIONER OF INCOME-TAX , DELHI
Income Tax Appellate Tribunal, DELHI BENCH ‘G’ : NEW DELHI
Before: SHRI MAHAVIR SINGH & SHRI S. RIFAUR RAHMANAsstt. Year : 2019-20
PER MAHAVIR SINGH, VP: This appeal by the Assessee is emanating from the order of the National Faceless Appeal Centre, (NFAC), Delhi in Appeal No. NFAC/2018-19/10337504 dated 24.07.2025. Assessment was framed by the ACIT, Circle 19(1), New Delhi u/s. 147 r.w.s. 144 of the Income Tax Act, 1961 (hereinafter referred the Act) vide order dated 04.03.2024 relating to assessment year 2019-20. 2. We have heard both the parties and perused the records. It is noted that AO has observed that the assessee had not been able to provide any explanation and documentary evidence in respect of aforesaid transactions and even not filed its ITR and Audited Financials. After perusal and consideration of the same, the reply
2 | P a g e filed by the assessee was found not tenable by the AO. Therefore, the transactions were added to the income of the assessee by passing an exparte order u/s. 147
r.w.s. 144 of the Act. It is further noted that Ld. CIT(A) also observed that assessee failed to respond the notices during the appellate proceedings further undermines its claim, as no submissions or evidences were provided to demonstrate that the AO overlooked material facts. It is also observed by the Ld. CIT(A) that in the absence of verifiable evidence, the AO’s decision to disregard insufficient submission is justified, hence, he upheld the additions made by the AO.
3. In view of the aforesaid factual matrix, we deem it fit and proper to remit back the issues to the file of the Assessing Officer to consider all the evidences /
documentary evidences and decide the issues in dispute afresh, after giving adequate opportunity of being heard to the assessee. Assessee is also directed to file the requisite documents and evidences, if any, in order to canvass its case and fully cooperate with the Assessing Officer during the proceedings.
4. In the result, the Assessee’s appeal is allowed for statistical purposes.
Order pronounced in the Open Court on 12.3.2026. (S. RIFAUR RAHMAN)
VICE PRESIDENT
Date: 19.03.2026
SRBhatnaggar