Held, that considering the totality of the facts of the case and in the interests of justice it was proper to restore the issue to the Commissioner (Appeals) with a direction to grant one final opportunity to the assessee to substantiate its case by filing the necessary documents and decide the issue as per fact and law. The assessee is  also hereby directed to participate in the appeal proceedings before the Commissioner (Appeals) by filing the requisite details without seeking any adjournment under any pretext failing which the Commissioner (Appeals) would be at liberty to pass appropriate order as per law.(AY. 2018-19)