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Income Tax Appellate Tribunal, DEHRADUN BENCH, DEHRADUN
Before: Sh. Satbeer Singh Godara & Sh. M. Balaganesh
Asstt. Year : 2018-19 Horrawal Kisan Sewa Sahkari Vs Income Tax Officer, Samiti Ltd., Horawala FSS Ward-1(1)(1), Horawala, Post Horrawal, Dehradun-248001 Dehradun-248001 (APPELLANT) (RESPONDENT) PAN No. AAGFH4362L Assessee by: Sh. Sushil Kumar, Adv. Revenue by: Sh. A. S. Rana, Sr. DR Date of Hearing: 20.03.2025 Date of Pronouncement: 23.04.2025 ORDER Per Satbeer Singh Godara, Judicial Member:
This assessee’s appeal for Assessment Year 2018-19, arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2024-25/1065449982(1) dated 06.06.2024, in proceedings u/s 147 of the Income Tax Act, 1961 (in short “the Act”).
Heard both the parties at length. Case file perused.
Learned counsel submits that on account of communication gaps at various levels, the assessee could not appear to plead and prove all the relevant facts in the lower appellate proceedings and therefore, in the larger interest of
Be that as it may, the fact remains that possibility of some communication gaps at various levels in such an instance of the newly introduced virtual hearing mechanism could not be altogether ruled out. This is indeed coupled with the facts that there is also no compliance to section 250(6) of the Act in the impugned lower appellate order stipulating points of determination to be framed followed by a detailed adjudication thereupon. It is therefore deemed appropriate in the larger interest of justice to set aside the assessee’s instant appeal back to the CIT(A)/NFAC for his afresh appropriate adjudication, within three effective opportunities of hearing at the appellant’s risk and responsibility, in consequential proceedings. Ordered accordingly.