2024 (12) TMI 559

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...., (in short referred to as "CIT(A)"), arising out of the reassessment order passed under section 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Year 2013-14. 2. This is the second round of appeal before this Tribunal. In the first round, the Ld. CIT(A) fixed the case for hearing on 31-07-2016 as there was no representation passed the exparte order on 28-12- 2016. On further appeal Co-ordinate Bench of this Tribunal set aside the matter back to the file of Ld. CIT(A) with a direction to decide the matter afresh on merits after giving opportunity of hearing to the assessee. Pursuant to the direction of this Tribunal, the Ld. CIT(A) had given hearing opportunities to the asses....

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....tional Faceless Appeal Centre wherein detailed written submissions and Paper Books in three parts already filed before NFAC. Therefore in the Interest of Justice, this present appeal also be set-aside to the file of NFAC for adjudicating on merits of the case by giving proper opportunity of hearing to the assessee. 4. Ld. CIT-DR could not contravent the above submissions of the assessee. 5. We have heard rival submissions and perused the materials available on record, impugned appellate order passed by NFAC. It is recorded that the appeal was instituted on 14-06-2016 and then migrated to NFAC in terms of the notifications issued by the CBDT. There is no reference about the ITAT's order dated 01-10-2018 in ITA No. 856/Ahd/2017 passed f....

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....some cases the taxpayers who were required to e-file Form 35, were unable to do so due to lack of knowledge about e-filing procedure and/or technical issues in e-filing. Also, the EVC functionality for verification of e-appeals was made operational from 12.05.2016 for individuals and from 19.05.2016 for other persons. Word limit for filing grounds of appeal and mapping of jurisdiction of Commissioners of Income Tax (Appeals) were also a cause of grievance in some cases. 2. The matter has been examined by the Board. While the underlying issues relating to e-filing of appeals have since been addressed and resolved, in order to mitigate any inconvenience caused to the taxpayers on account of the new requirement of mandatory e-filing a....