What did the Tribunal hold?

The Tribunal observed that the additional claims were not decided and needed to be examined by the AO. Therefore, the appeal was restored to the file of the AO with a direction to decide these claims.

The assessee made additional claims before the Assessing Officer (AO) and the Commissioner of Income Tax (Appeals) (CIT(A)). These claims were not decided by either authority in their respective orders.

What were the issues?

Whether additional claims made by the assessee, which were not adjudicated by the lower authorities, should be decided by the Assessing Officer.

Pricewaterhouse Coopers Private… vs DCIT | ITAT Kolkata 2026

Income Tax Appellate Tribunal, KOLKATA ‘D’ BENCH, KOLKATA

Before: SHRI DUVVURU R.L. REDDY, VICE- & SHRI RAJESH KUMAR

For Appellant: Shri K.M. Gupta, AR

For Respondent: Shri S. B. Chakraborthy, Sr. DR

Hearing: 14.05.2026Pronounced: 25.06.2026

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘D’ BENCH, KOLKATA BEFORE SHRI DUVVURU R.L. REDDY, VICE-PRESIDENT AND SHRI RAJESH KUMAR, ACCOUNTANT MEMBER I.T.A. No.2368/KOL/2025 (Assessment Year:2018-19) Pricewaterhouse Coopers Pvt. Ltd., DCIT, Block – EP, Plot – Y-14, Salt Lake Vs. Circle – 1(1), City, Sector – V, Kolkata - 700091 Kolkata [PAN:AABCP9181H] (Appellant) .. (Respondent) Appellant by : Shri K.M. Gupta, AR Respondent by: Shri S. B. Chakraborthy, Sr. DR Date of Hearing 14.05.2026 Date of Pronouncement 25.06.2026

O R D E R PER RAJESH KUMAR, ACCOUNTANT MEMBER:

This appeal preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals),(hereinafter referred to as the “Ld.CIT(A)”],National Faceless Appeal Centre (NFAC), dated 13.08.2025 for the Assessment Year (AY) 2018-19.

At the outset, the Learned Authorized Representative (Ld. AR) submitted that assessee made certain additional claims before the Assessing Officer (In short, ‘AO’) as well as Ld. CIT(A), which were not decided by the respective authorities in the order passed by them. The Ld. AR prayed that the appeal may be restored to the file of AO with a direction to decide these additional claim/issue after taking into account the facts qua these claims and

ITA No.2368/Kol/2025/AY 2018-19 Pricewaterhouse Coopers Pvt. Ltd. also submissions of the assessee. On the other hand, the Ld. Sr. DR did not oppose the argument of the Ld. AR.

After hearing the rival parties and perusing the material on record, we observe that the additional claim raised by the assessee before the AO as well as the Ld. CIT(A) which were not decided by the respective authorities in their orders. We have also examined the factual aspects of the claims before us and are of the considered opinion that these need to be examined and adjudicated by the AO after looking into the facts. Consequently, we restore appeal back to the file of AO with a direction to decide these additional claims after taking into account and the submission made by the assessee in accordance with law.

In the result, the appeal of the assessee is allowed for statistical purposes.

The order is pronounced in the open Court on 25/06/2026.

Sd/- Sd/- (Duvvuru R. L. Reddy) (Rajesh Kumar) VICE PRESIDENT ACCOUNTANT MEMBER Kolkata, Dated: 25/06/2026 SAMANTA आदेश �ȧ ĤǓ�ͧ �ͪ �\ Ē ȯͪ��/Copy of the Order forwarded to : 1. \ �Ȣ�ȡ�ȸ/ The Appellant 2. Ĥ×��ȸ/ The Respondent. 3. Ȳ�Ȳͬ��आयकर] �ǕÈ�/ Concerned CIT 4. आयकर] �ǕÈ�(अपील) / The CIT(A)- 5. ��ȡ�Ȣ�ĤǓ�Ǔ�ͬ �, आयकर\ �Ȣ�ȣ�\ͬ ��,/ DR, ITAT, Kolkata 6. �ȡ�[ फाईल/ Guard file.

BY ORDER, // TRUE COPY //

Asstt.Registrar, ITAT, Kolkata

PRICEWATERHOUSE COOPERS PRIVATE LIMITED,KOLKATA vs. DCIT CIRCLE 1(1), KOLKATA

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