2024 (3) TMI 477

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..... T:- Revenue could hardly dispute the clinching fact that the NFAC s order has nowhere decided the assessee s substantive grounds on merits as contemplated u/sec.250(6) of the Act requiring it to give points for determination followed by a detailed discussion thereof. Faced with the situation, we deem it appropriate in the larger interest of justice to restore the assessee s instant appeal back to .....

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..... s appeal for assessment year 2011-12, arises against the National Faceless Appeal Centre [in short the NFAC ] Delhi s Din and Order No. ITBA/NFAC/S/250/2023- 24/1058132923(1), dated 22.11.2023, involving proceedings u/s.144 of the Income Tax Act, 1961 (in short the Act ). Heard Both the parties. Case file perused. 2. It emerges during the course of hearing that the NFAC has noted the assessee s c .....

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..... accordingly. 3. The impugned delay of 4 days herein is condoned as per assessee s solemn averments in light of Collector, Land Acquisition vs., MST Katiji [1987] 167 ITR 471 (SC) having settled the law long back that all such technical aspects must make a way for the cause of substantial justice. 4. This assessee s appeal is allowed for statistical purposes in above terms. Order pronounced in the .....

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