https://www.taxtmi.com/caselaws?id=751007 ITAT Panaji condoned delay in filing appeal and set aside CIT(A)'s order for de-novo adjudication. The case involved addition under section 69 based on difference between 26AS statement and income return. ITAT held that both Assessing Officer failed to conduct proper investigations despite having access to earlier years' returns, and CIT(A) failed to adjudicate grounds on merits or consider Rule 46A documents. Citing SC precedent in Gupta Emerald Mines and HC decision in Hindalco Industries, ITAT emphasized substantial justice over technical delays. Appeal allowed for statistical purposes with matter remanded to CIT(A) for fresh consideration. en-us Wed, 28 Feb 2024 00:00:00 +0530 Tue, 27 Aug 2024 12:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751007 ITAT Panaji condoned delay in filing appeal and set aside CIT(A)'s order for de-novo adjudication. The case involved addition under section 69 based on difference between 26AS statement and income return. ITAT held that both Assessing Officer failed to conduct proper investigations despite having access to earlier years' returns, and CIT(A) failed to adjudicate grounds on merits or consider Rule 46A documents. Citing SC precedent in Gupta Emerald Mines and HC decision in Hindalco Industries, ITAT emphasized substantial justice over technical delays. Appeal allowed for statistical purposes with matter remanded to CIT(A) for fresh consideration. Case-Laws Income Tax Wed, 28 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751007