2025 (3) TMI 1882

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....t Sharma, CIT DR ORDER PER RAJPAL YADAV, VP The assessee is in appeal before the Tribunal against the order of the ld.Commissioner of Income Tax (Appeals) [in short 'the CIT (A)'] dated 28.08.2024 passed for assessment year 2011-12. 2. The assessee has taken seven grounds of appeal but her grievance revolves around two issues namely, (a) The ld. CIT(A) has erred in upholding the re-ope....

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....l Year 2011-12 relevant for assessment year 2012-13. Therefore, no addition can be made in assessment year 2011-12. He placed on record the copy of the Purchase Deed and other details. 6. The ld. CIT DR, on the other hand contended that assessee did not appear before the AO. It is not discernible whether assessee has filed any application for additional evidence before the CIT(A). Thus, these d....

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.... the assessee has escaped but he has not done any such exercise. The assessee is equally negligent. He did not respond to the AO nor put efforts to place on record these documents before the CIT(A). Thus, considering the contributory negligence, we deem it appropriate to restore this issue to the file of AO for fresh examination. Both the impugned orders are set aside. The issue is relegated to th....