Ex parte assessment remanded for fresh verification where evidence and explanations were not effectively examined.

Ex parte assessment and first appellate proceedings were completed without effective compliance by the assessee and without adequate evidentiary material or explanations on record, so the dispute required fresh factual verification. The record also indicated that additional material had been filed before the first appellate authority, but its consideration had to be tested against the rules governing additional evidence. Given the incomplete examination of the issues, the impugned order was set aside and the matter was remanded to the Assessing Officer for de novo assessment after verification of the evidence and explanations to be furnished by the assessee.

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Issues: Whether the ex parte assessment and first appellate order, passed without effective evidence or submissions and during the COVID-19 period, should be set aside and the matter remanded for fresh assessment.

Analysis: The assessment and first appellate proceedings were completed in the absence of any effective compliance by the assessee and without cogent material or explanations on record. The record indicated that the assessee had not meaningfully participated, while the circumstances were also linked to the COVID-19 restrictions. Additional material was stated to have been filed before the first appellate authority, but the record suggested that the matter required consideration in the light of the procedural requirements governing additional evidence. In such a situation, where the dispute was decided without adequate evidentiary examination, a remand for proper verification was considered appropriate.

Conclusion: The impugned order was set aside and the matter was remanded to the Assessing Officer for de novo assessment after verification of the issues on the basis of evidence and explanations to be furnished by the assessee.

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