ITAT Remands Reassessment Case to CIT(A) for Fresh Adjudication of Legal Grounds:

The assessee is an individual and non-filer, was subjected to reassessment proceedings for AY 2020-21. The AO completed the assessment under Section 147 read with Sections 144 and 144B of the Income Tax Act, 1961, vide order dated 04/03/2025, determining the assessee's total income at Rs. 43,41,558. The assessment included an addition of Rs. 31,42,558 under Section 56(2)(vii)(b)(ii) in respect of an immovable property transaction and a further addition of Rs. 11,99,000 under Section 69 towards unexplained investment.

Aggrieved by the assessment, the assessee preferred an appeal before the CIT(A), challenging both the additions and the legality of the reassessment proceedings. However, the CIT(A), through order dated 02/01/2026, dismissed the appeal without properly dealing with several legal grounds raised by the assessee.

The Tribunal observed that the CIT(A) had summarily dismissed the assessee's appeal without adjudicating important legal grounds concerning the validity of the reassessment proceedings, particularly the jurisdiction of the AO and the manner in which approval under Section 151 was granted. The Tribunal further noted that certain legal issues had been raised before it for the first time, while some grounds raised before the CIT(A) had not been adjudicated.

Considering the nature of these grounds, and the fact that several grounds remained unadjudicated, the Tribunal considered it appropriate to remit the legal and other issues to the file of the CIT(A) for necessary adjudication. Accordingly, the Tribunal set aside the appellate order and allowed the assessee's grounds for statistical purposes.