FOUR STAR HOSPITALITIES LLP,GHAZIABAD vs. ACIT RANGE 4, NEW DELHI

Heard both the parties at length. Case files 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, the corresponding mitigating circumstances involving cash payments and loan herewith etc. in both the lower proceedings and therefore, in the larger interest of justice met in case, the matter(s) be restored back to the Assessing Officer.

This is indeed coupled with the facts that there is also no effective 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 all four appeals back to the learned Assessing Officer for his afresh appropriate adjudication, within three effective opportunities of ITA Nos. 1792 to 1795/Del/2025 Four Star Hospitalities LLP 3 hearing at the assessee’s risk and responsibility, in consequential proceedings. Ordered accordingly.

These assessee’s four appeals ITA Nos. 1792 to 1795/Del/2025 are allowed for statistical purposes. A copy of this common order be placed in the respective case files. Order Pronounced in the Open Court on 01/09/2025. (S. Rifaur Rahman) (Satbeer Singh Godara) Accountant Member Judicial Member