AKANSHA GARG,DELHI vs. ACIT,CIRCLE INT. TAX-1(3)(1), DELHI

PER YOGESH KUMAR, U.S. JM:

The present appeal is filed by the Assessee against the Final
Assessment Order passed u/s 143(3) r.w.s. 144C(13) of the Act by the Assistant Commissioner of Income Tax, Circle, Intl. Tax-1(3)(1), dated
06/01/2025 for the Assessment Year 2022-23. 2. In consequent to the directions of the DRP, the A.O. passed the Final Assessment Order on 06.01.2025 u/s 143(3) r.w.s. 144C(13) of the 2
AkanshaGarg

Act. Aggrieved by the Final Assessment Order on 06.01.2025, the Assessee preferred the present appeal.
3. During the course of hearing, the Assessee filed an application for admission of additional documents under Rule 27 of the ITAT Rules,
1963 and contended that the Revenue decided the case of the Assessee based on the document issued by the Karur Vysya Bank dated
23.04.2024 detailing the amounts of FDRs which were renewed by the Assessee during the year and the amounts of FDRs which were made afresh during the financial year 2021-22. The ld. AR submitted that the Assessee obtained the said document from Karur Vysya Bank only after passing of the draft assessment order u/s 144C of the Act.
4. We have heard both the parties and perused the material available on the record.
5. It is evident that the said Karur Vysya Bank has issued certificate only after passing of the draft assessment order u/s 144C of the Act, which deprived the Assessee from producing the same before the DRP which ultimately resulted in passing the order impugned. Therefore, the interest of justice, we admit the additional evidence produced by the Assessee and remand the matter to the file of the A.O. for verification of 3
AkanshaGarg the document and to decide the issue afresh by taking due cognizance of the said document along with other materials on record.
6. In the result, the Appeal of the Assessee is partly allowed for statistical purpose.
Order pronounced in the open court on 19th September, 2025 (S. RIFAUR RAHMAN)
JUDICIAL MEMBER
Date:- 19 .09.2025
Subodh, Sr.P.S*