Sec. 251 of the Income-tax Act, 1961 - Appeal - Supreme Court while setting aside the aside the impugned orders of the High Court, ITAT and the CIT(A) respectively relegated the parties before CIT(A) for reconsideration of appeal(s) on its own merits in accordance with law holding that “one of the issues involved is about not extending opportunity to the appellant to cross-examine the witnesses relied upon by the AO. If the Department wants to rely on their evidence, it may be necessary to provide opportunity of cross-examination of these witnesses to the appellant, which can be done by the First Appellate Authority itself, namely, Commissioner of Income-tax (Appeals)-I, Bangalore. We say so because both parties intend to rely on some additional documents and circumstances. The First Appellate Authority may reconsider the matter afresh on its own merits in accordance with law including by examining the additional material/circumstances to be produced by the parties”. - I.C.D.S. LTD. V/s CIT - [2020] 273 TAXMAN 012 (SC)