https://www.taxtmi.com/caselaws?id=789107 An appellate order that addresses reassessment proceedings instead of the regular assessment under section 143(3) is unsustainable where it reflects a factual mismatch and does not decide the correct controversy. In such circumstances, the proper course is to set aside the order and remit the matter for fresh adjudication on the correct assessment record after granting the assessee a proper opportunity of hearing. The ITAT Ahmedabad accordingly restored the matter to the appellate authority for decision on merits, leaving the underlying addition undecided and treating the appeal as allowed for statistical purposes. en-us Fri, 20 Feb 2026 00:00:00 +0530 Fri, 03 Apr 2026 08:49:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789107 An appellate order that addresses reassessment proceedings instead of the regular assessment under section 143(3) is unsustainable where it reflects a factual mismatch and does not decide the correct controversy. In such circumstances, the proper course is to set aside the order and remit the matter for fresh adjudication on the correct assessment record after granting the assessee a proper opportunity of hearing. The ITAT Ahmedabad accordingly restored the matter to the appellate authority for decision on merits, leaving the underlying addition undecided and treating the appeal as allowed for statistical purposes. Case-Laws Income Tax Fri, 20 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789107