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2020 (5) TMI 234 - AT - Income TaxAdditions of Unexplained receipt on protective basis - HELD THAT:- On consideration of submission of Ld. CIT-DR which could not be controverted by Ld. Representatives of concerned assessees, that the divergent view have been taken by the appellate authorities below, we are of the view that in the interest of justice and fair play the present impugned orders are required to be set aside with direction to Ld. CIT(A) to decide the appeals de novo in the light of aforesaid facts. Accordingly, the issues raised in the present appeals are remitted back to the file of the CIT(A) for deciding the same afresh as per law with direction that the ld. CIT(A) would decide the appeals relating to substantive proceedings at first and thereafter the appeals relating to protective assessments.
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