GOVIND MURLIDHAR SAMANT,MUMBAI vs. ASSESSING OFFICER NATIONAL FACELESS ASSESSMENT CENTREMENTDELHI, DELHI

Heard both the parties at length. Case file perused.

Learned counsel submits at the outset that the assessee’s former appeal herein be dismissed as not pressed being “duplicate” in nature. Ordered accordingly.

Next comes the assessee’s latter appeal raising the following substantive grounds:

It emerges at the outset with the able assistance coming from both the parties that the CIT(A)/NFAC’s impugned lower appellate order herein has nowhere considered merits of the assessee’s sole substantive grievance seeking to reverse section 69 addition(s) of Rs.18,53,588/- and u/s 56(2) to the tune of Rs.57,32,000/-, made in the course of assessment dated 18.05.2023, by either framing the points of adjudication or a detailed adjudication thereupon, as contemplated under section 250(6) of the Act.

Learned counsel Mr. Manish Ajudiya at this stage invited our attention to page No.13 in the lower appellate discussion that the CIT(A) had indeed afforded sufficient opportunities to the assessee which the latter failed to avail. We find no merit in the Revenue’s instant technical argument once the CIT(A) has not even dealt with the relevant factual matrix of the assessee’s pleadings as indicated in preceding paras. We accordingly deem it appropriate to restore the assessee’s instant twin substantive grounds back to the CIT(A)/NFAC for effective opportunities of hearing. Ordered accordingly.

To sum up, the assessee’s former appeal is dismissed and his latter case ITA No.2090/M/2024 is allowed for statistical purposes in above terms. A copy of this common order be placed in the respective case files.