Fresh opportunity in insolvency-linked non-compliance led to remand of assessment with costs.

An assessment was restored for fresh consideration because the assessee had not complied before the lower authorities, but the record showed the company was under corporate insolvency resolution process and represented through the resolution framework. In these circumstances, the Tribunal granted one final opportunity to place the required details before the Assessing Officer, balancing procedural fairness against earlier non-compliance. Costs were imposed to reflect the assessee's failure to respond despite repeated notices.

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Issues: Whether the assessee should be granted one last opportunity and the matter remanded to the Assessing Officer in view of the assessee's inability to comply during insolvency proceedings.

Analysis: The assessee had not furnished the required details before the lower authorities despite repeated notices, but the record showed that the company was under corporate insolvency resolution process and was being represented through the resolution framework. In these circumstances, and considering the nature of the additions and the substantial quantum involved, the Tribunal found it appropriate to afford one final opportunity to the assessee to present its case before the Assessing Officer. To balance the opportunity granted with the assessee's earlier non-compliance, costs were also imposed.

Conclusion: The matter was restored to the Assessing Officer for fresh consideration after giving the assessee one last opportunity, with costs.

Ratio Decidendi: Where the assessee's non-compliance is linked to insolvency proceedings and the interests of justice require a fresh hearing, the Tribunal may remand the assessment while imposing costs.

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