2025 (12) TMI 841

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....ue : Shri Annavaran Kosuri ORDER PER AMIT SHUKLA (J.M): These three appeals, being ITA Nos. 5807/Mum/2025 to 5809/Mum/2025, have been preferred by the assessee against the order dated 27/08/2025 passed for A.Y. 2016-17- one arising from the quantum assessment framed under Section 147 r.w.s. 144 of the Income-tax Act, 1961, and the remaining two emanating from the penalty orders passed sep....

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....e the notices issued by the Assessing Officer during reassessment or those issued by the learned CIT(A), and therefore could not attend or make representations before either authority. For the same reason, two separate penalties eventually came to be levied - one under Section 271(1)(b) for non-compliance with notices and another under Section 271(1)(c) consequent to the confirmation of the additi....

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....r as well as the learned CIT(A). In the larger interest of justice and so that no assessee is prejudiced without being heard, we consider it appropriate to restore the entire matter to the file of the Assessing Officer, who shall adjudicate the issues afresh strictly in accordance with law after granting due and effective opportunity of hearing to the assessee. The assessee shall in turn cooperate....