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IN THE INCOME TAX APPELLATE TRIBUNAL

“SMC” BENCH, CHANDIGARH

PHYSICAL HEARING

HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

1. आयकर अपील सं. / ITA No.234/CHANDI/2026

(िनधा(cid:330)रणवष(cid:330) / Assessment Year: 2020-21)

&

2. आयकर अपील सं. / ITA No.235/CHANDI/2026

(िनधा(cid:330)रण वष(cid:330) / Assessment Year: 2020-21)

Shri Raj Kumar ITO Ward – 3

C/o Rajiv Goel and Associates Kurukshetra

बनाम/ Vs.

179, Bank Road, Ambala Cantt.

Haryana – 133001

(cid:725)ायीलेखासं./जीआइआरसं./PAN/GIR No. AQFPK-0368-L

(अपीलाथ५/Appellant) : (ঋ(cid:529)थ५ / Respondent)

अपीलाथ५कीओरसे/ Appellant by : ^{Sh. Rohit Goel (CA) – Ld. AR}

ঋ(cid:529)थ५कीओरसे/Respondent by : Dr. Ranjit Kaur (Addl. CIT) - Ld. Sr. DR

सुनवाईकीतारीख/Date of Hearing : 16-07-2026

घोषणाकीतारीख /Date of Pronouncement 23-07-2026

:

आदेश / O R D E R

1. Aforesaid appeals by assessee for Assessment Year (AY) 2020-

21 assail quantum assessment as well as levy of penalty u/s

272A(1)(d). The Ld. AR, at the outset, sought remand back of

quantum appeal to lower authorities on the ground that the assessee

could not represent therein. The same has been opposed by Ld. Sr.

DR. The Ld. AR stated that the assessee is in a position to

substantiate its case.

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2. In the assessment order, Ld. AO made various additions to

determine total income at Rs.16.42 Lacs for want of substantive

representation from the assessee. The Ld. AO also levied penalty of

Rs.20,000/- u/s 272A(1)(d) for assessee’s failure to respond to

hearing notices. The Ld. CIT(A) confirmed the assessment as well as

the penalty for the same very reasons. Aggrieved, the assessee is in

further appeals before Tribunal. It is the submission of Ld. AR that the

assessee has received retirement benefits and accordingly, the

assessee is in a position to substantiate its case before lower

authorities. It has further been stated that non-appearance was not

willful.

3. Keeping in mind the principles of natural justice and considering

the background of the assessee, I delete impugned penalty as levied

u/s 272A(1)(d). The quantum assessment is set aside and the matter

is restored back to Ld. AO for de novo assessment with a direction to

the assessee to plead and prove its cases forthwith.

3. ITA No.235/Chandi/2026 stand allowed. ITA No.234/Chandi/2026

stand allowed for statistical purposes.

Order pronounced on 23rd July, 2026.

-Sd-

(MANOJ KUMAR AGGARWAL)

ACCOUNTANT MEMBER

AS

Dated: 23/07/2026

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आदेश की (cid:366)ितिलिप अ(cid:356)ेिषत /Copy of the Order forwarded to :

1. अपीलाथ५/Appellant

2. ঋ(cid:529)थ५/Respondent

3. आयकरआयुঢ/CIT

4. िवभागीयঋितिनिध/DR

5. गाड१फाईल/GF

ASSISTANT REGISTRAR

ITAT CHANDIGARH