RAIDENBIT INTERACTIVE PRIVATE LIMITED,DELHI V. ASSESSING OFFICER, NATIONAL FACELESS APPEAL CENTRE (NFAC)

ITA 8113/DEL/2025

AI Insights

The case involves Raidenbit Interactive Pvt. Ltd., which appealed against the order of the National Faceless Appeal Centre (NFAC), Delhi, concerning the assessment year 2022-23. The primary issues in the appeal were the treatment of share capital/premium amounting to Rs.6,76,72,921, unexplained investments in mutual funds, and sales promotion expenditures, which were deemed not allowable by the lower authorities. The tribunal found that the additional evidence submitted by the assessee was not considered by the lower appellate authority as required under section 250(6) of the Income Tax Act, 1961. Consequently, the tribunal remanded the case back to the CIT(A)/NFAC for a thorough examination of the additional evidence and proper adjudication.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 842141 (ITAT-DELHI)
• Duration Of Justice: 2 month(s) 20 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-02-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: F
• Assessment Year: 2022-2023
• Appeal Filed On: 04-12-2025
• Laws Referred To: Income-tax Act, 1961
• Result in Favour of: Matter Remanded
• Court: TRIBUNAL
• Department Lawyers: HARPREET KAUR HANSRA
• Assessee Lawyers: RAJESHWAR PAINULY
• Keywords: Additional evidence; Unexplained investment; Search and seizure
• Section: 143(3)

Judgement Text

"P a g e | 1 ITA No.8113/Del/2025 Raidenbit Interactive Pvt. Ltd. (AY: 2022-23) IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No.8113/Del/2025 (Assessment Year 2022-23) Raidenbit Interactive Private Limited 2392/1, Khasra No.311/22 Ground Floor, Village, Shadipur, Ranjit Nagar, Patel Nagar, Central Delhi Delhi – 110008 Vs. Assessing Officer, National Faceless Appeal Centre (NFAC) Delhi \u0001थायीलेखासं./जीआइआरसं./PAN/GIR No: AAJCR5969B Appellant .. Respondent Appellant by: Sh. Rajeshwar Painuly, Adv. Respondent by: Ms. Harpreet Kaur Hansra, Sr. DR Date of Hearing 24.02.2026 Date of Pronouncement 24.02.2026 O R D E R PER SATBEER SINGH GODARA, JM: This assessee’s appeal for assessment year 2022-23 arises against the order of National Faceless Appeal Centre, Delhi dated 29.09.2025 Printed from counselvise.com P a g e | 2 ITA No.8113/Del/2025 Raidenbit Interactive Pvt. Ltd. (AY: 2022-23) (hereinafter referred as the ‘First Appellate Authority’) DIN and Order No. ITBA/NFAC/S/250/2025-26/1081296124(1), involving proceedings u/s 143(3) r.w.s 144B of the Income-tax Act, 1961, [hereinafter referred to as the ‘Act’] passed by the Assessment Unit, Income Tax Department for AY: 2022-23. 2. Heard both parties at length. Case file perused. 3. It transpire during the course of hearing that the assessee/appellant is aggrieved against both the Learned lower authorities action interalia treating its share capital/premium of Rs.6,76,72,921/- as well as unexplained investments in mutual funds and sales promotion expenditure etc. involving varying sums as not allowable in assessment order dated 19.03.2024 as upheld in the lower appellate discussion. 4. That being the case, we invited the assessee’s contention to para 5 at page 5 of the lower appellate discussion holding it not to have filed its complete details in support of its various factual and legal ground raised therein. Faced with this situation, learned counsel submits that the assessee had very much filed its submission in assessment followed by additional evidence before the CIT(A)/NFAC under Rule 46A of the Income Tax Rules. Printed from counselvise.com P a g e | 3 ITA No.8113/Del/2025 Raidenbit Interactive Pvt. Ltd. (AY: 2022-23) The fact however remains that no such details have been considered in the lower appellate discussion as contemplated u/s 250(6) of the Act. 5. We deem it proper in this factual backdrop to restore the assessee’s instant appeal back to the CIT(A)/NFAC with a direction that it shall file its entire evidence as well as additional evidence, if any, in consequential proceeding which shall follow a remand report to be obtained from the Assessing Officer within three effective opportunities of hearing at the taxpayer’s risk and responsibility only. We order accordingly. It is made clear that moreover the assessee fails to plead and prove its case in the given number of effective opportunities, our remand direction shall be stood vacated in above terms. 6. This assessee’s appeal is allowed for statistical purposes. Order pronounced in the open court on 24.02.2026 Sd/- (Naveen Chandra) Sd/- (Satbeer Singh Godara) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated 25.02.2026 Rohit, Sr. PS Printed from counselvise.com P a g e | 4 ITA No.8113/Del/2025 Raidenbit Interactive Pvt. Ltd. (AY: 2022-23) Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI Printed from counselvise.com "