2026 (3) TMI 470

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....il Choudhari, Sr. DR ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against order dated 12.09.2025 passed by the Ld. Commissioner of Income-tax (Appeals) - National Faceless Appeal Centre, Delhi [in short 'the Ld. CIT(A)'] for assessment year 2020-21, raising following grounds: 1. The Hon'ble CIT (A) [NFAC] has erred in passing an Ex-parte Appellate Ord....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....g of this appeal. 5. The appellant therefore prays that the addition/ disallowance made by the Ld. Assessing Officer and subsequently upheld by Hon'ble CIT (A) may please be deleted and/or alternatively the appellate order passed by the Hon'ble CIT (A) in an Ex-parte manner and Assessment order passed by the Ld. Assessing Officer may please be restored back to Hon'ble CIT (A) ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....esponsive to three statutory notices issued between November 2024 and August 2025. Applying the legal maxim "Vigilantibus non dormientibus jura subveniunt" (the law assists the vigilant, not those who sleep over their rights), the Ld. CIT(A) concluded that the assessee was not interested in pursuing the appeal. Relying on the ratio in CIT vs. B. N. Bhattacharya [118 ITR 461], the Ld. CIT(A) dismis....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....rd. While we acknowledge the Ld. CIT(A)'s reliance on judicial discipline and the need for timely disposal, we must also consider the higher principle of the right to be heard. 3.1 The transition to a faceless and digital appellate regime is intended to enhance efficiency, but it must not become a barrier to justice for those who lack the technical proficiency to navigate such systems. The Hon'....