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“Section 251(2)”

Section References (mined)Section 251Section 251(2)645 judgments

The decision most relied on for Section 251(2) is Jute Corporation of India Ltd. v. CIT (187 ITR 688), cited in 1,372 judgments on BharatTax.

Leading authorities on Section 251(2)

Jute Corporation of India Ltd. v. CIT
187 ITR 688 · 1991 · Supreme Court
1,372
citing judgments

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

CIT v. Premkumar Arjundas Luthra (HUF)
297 CTR 614 · 2017 · High Court
659
citing judgments

The Commissioner of Income-tax (Appeals) cannot dismiss an appeal for non-prosecution or default in appearance. Under Section 250(6) of the Income-tax Act, the CIT(A) must decide the appeal on its merits, even in an ex parte proceeding.

Skycell Communications Ltd. v. DCIT
251 ITR 53 · 2001 · High Court
253
citing judgments

Technical services involve human intervention and expertise, not just routine or machine-based operations. Routine customer support and standard facility provision through technology do not constitute technical services under the Act.

CIT v. Claris Lifesciences Ltd.
326 ITR 251 · 2010 · High Court
196
citing judgments

If approval from the Department of Scientific and Industrial Research (DSIR) for an in-house R&D centre is granted during the previous year, the assessee is entitled to claim weighted deduction under section 35(2AB) for the entire expenditure incurred during that year.

Berger Paints India Ltd. v. CIT
266 ITR 99 · 2004 · Supreme Court
181
citing judgments

The Revenue cannot take a conflicting stand from what it had earlier accepted in a previous assessment year without compelling justification. This principle of consistency applies to various issues, including the treatment of customs duty in closing inventory.

Income Tax-III, Pune v. Rajasthan & Gujarati Charitable Foundation Poona
89 Taxmann.com 127 · 2018 · Supreme Court
130
citing judgments

The claim of depreciation under Section 32 of the Income Tax Act for assets used by charitable trusts is permissible, affirming the Bombay High Court's view that such a claim does not amount to a 'double benefit'.

CIT v. Karnataka State Co-operative Apex Bank
251 ITR 194 · 2001 · Supreme Court
106
citing judgments

Interest income earned by a co-operative bank from statutory investments or mandatory deposits, which are essential for conducting its banking business, qualifies as business income and is exempt under Section 80P(2)(a)(i) of the Income-tax Act.

PCIT v. Chain House International (P) Ltd.
98 Taxmann.com 47 · 2018 · High Court
104
citing judgments

The Assessing Officer cannot arbitrarily reject a share valuation report prepared by an expert using recognized methods like NAV or DCF for the purpose of Section 56(2)(viib) without providing valid reasons to demonstrate its perversity or unreasonableness.

Judgments citing Section 251(2)

Shakeel Abdul Azeez Mohammad, Jalgaon vs. ITO, Ward 1(1), Jalgaon

In the result, appeal of the assessee is allowed for statistical purpose

ITA 1115/PUN/2025[2016-17]Status: DisposedITAT Pune21 Jul 2025AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपीलसं. / Ita No.1115/Pun/2025 िनधा"रण वष" / Assessment Year: 2016-17 Shakeel Abdul Azeez V The Income Tax Officer, Mohammad, S Ward-1(1), Jalgaon. Kachchi Chawl, Indira Nagar, Shahu Nagar, Jalgaon-425001. Maharashtra. Pan: Byfpm1596K Appellant/ Assessee Respondent / Revenue Assessee By Shri Vinay V Kawdia – Ar(Virtual) Revenue By Shri Sandeep P Sathe – Jcit(Dr) Date Of Hearing 17/07/2025 Date Of Pronouncement 21/07/2025

Section 144Section 147Section 148Section 153CSection 250Section 69A

prosecution of the appeal by the assessee. This is amply clear from the Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act which requires the CIT(A) to apply his mind to all the issues which arise from the impugned order before him whether

M/S Chhanabhai Kanjibhai Patel, Surat vs. Assistant Commissioner of Income Tax Circle 2(2)), Surat

In the result, appeal of the assessee is treated as allowed

ITA 757/SRT/2024[2017-18]Status: DisposedITAT Surat18 Jul 2025AY 2017-18

Bench: MS SUCHITRA RAGHUNATH KAMBLE (Judicial Member), SHRI BIJAYANANDA PRUSETH (Accountant Member)

Section 133(6)Section 143(3)Section 250Section 251(1)(a)Section 41(1)Section 68

opportunity of hearing before enhancement of income in the appellate order. Since the CIT(A) has failed to follow the mandatory requirement of Section 251(2) of the Act, the enhancement is not liable to be sustained. Accordingly, ground raised by appellant is allowed. 8. In the result, appeal

Kolan Vanaja, Hyderabad vs. ITO, Ward-15(1), Hyderabad

The appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 297/HYD/2025[2015-16]Status: DisposedITAT Hyderabad18 Jul 2025AY 2015-16

Bench: Us:

For Appellant: Smt. S. Sandhya, AdvocateFor Respondent: Shri Gurpreet Singh, Sr.DR
Section 147Section 148Section 148ASection 69A

आयकर अपीलीय न्यायाधिकरण में, हैदराबाद ‘ए’ बेंच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ A ‘ Bench, Hyderabad श्री रवीश

Rakesh Pandey, Baloda Bazar vs. Income Tax Officer, Bhatapara, Bhatapar

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

ITA 314/RPR/2025[2016-17]Status: DisposedITAT Raipur17 Jul 2025AY 2016-17

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.314/Rpr/2025 "नधा"रण वष" /Assessment Year : 2016-17 Rakesh Pandey 274, Sadar Lane, Mahamaya Chowk Lawan, Bhatapara-493 626 Pan: Ajgpp8840C .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer Bhatapara (C.G.) ……""यथ" / Respondent

For Appellant: Shri Paveen Goyal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 250Section 250(6)Section 251(1)(a)Section 251(2)

आयकर अपील"य अ"धकरण "यायपीठ “एक-सद"य” मामला रायपुर म" IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH

Sudhir Jaiswal, Kolkata vs. ITO, Ward 37(1), Kolkata

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

ITA 644/KOL/2025[2015-16]Status: DisposedITAT Kolkata17 Jul 2025AY 2015-16

Bench: Shri Duvvuru Rl Reddy & Shri Rakesh Mishraassessment Year: 2015-16

For Appellant: Shri Prabhat Kumar Singh and Shri Anuj Musaddi, ARsFor Respondent: Shri Sanat Kumar Raha &
Section 144Section 144BSection 147Section 148Section 250Section 250(6)Section 68Section 69C

prosecution of the appeal by the assessee. This is amply clear from the Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act which requires the CIT(A) to apply his mind to all the issues which arise from the impugned order before him whether

Shweta Pareshkumar Jain, Surat vs. ITO, Ward 2(3)(4), Surat

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 275/SRT/2025[2011-12]Status: DisposedITAT Surat16 Jul 2025AY 2011-12

Bench: Shri T.R.Senthil Kumar & Shri Bijayananda Prusethassessment Year : 2011-12 Shweta Pareshkumar Jain The Income Tax Officer V/S. C-904 Jolly Residency Ward-2(3)(4) Nayapura Karva Road Surat – 395 001 Vesu, Surat – 395 007 Pan: Askpp 6811 E (Appellant) (Respondent) Assessee By : Shri Mehul Shah, Ca Revenue By : Shri Ajay Uke, Sr.Dr Date Of Hearing : 03/07/2025 Date Of Pronouncement: 16/07/2025 O R D E R Per T.R.Senthil Kumar: This Appeal Is Filed By The Assessee As Against The Ex-Parte Appellate Order Dated 31/01/2025 Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”] Arising Out Of The Re-Assessment Order Passed U/S.147 R.W.S.144 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) Relating To The Assessment Year (Ay) 2011- 12. 2. The Brief Facts Of The Case Are That The Assessee Is An Individual Has Not Filed The Return Of Income Relating To The Ay 2011-12. The Assessee Had Carried Out Transactions In Bombay Stock Exchange To Shweta Pareshkumar Jain Vs. Ito Asst. Year : 2011-12

For Appellant: Shri Mehul Shah, CAFor Respondent: Shri Ajay Uke, Sr.DR
Section 147Section 148Section 251(2)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH, SURAT [conducted through Hybrid mode] ] ] BEFORE SHRI T.R.SENTHIL KUMAR JUDICIAL MEMBER AND

Ratilal Karmshi Patel, Satara vs. ITO Ward 1, Satara

In the result, appeal of the assessee is allowed for statistical purpose

ITA 1399/PUN/2025[2022-23]Status: DisposedITAT Pune16 Jul 2025AY 2022-23

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं./Ita No.1399/Pun/2025 िनधा"रण वष" / Assessment Year: 2022-23 Ratilal Karmshi Patel, V The Income Tax Officer, D-70, Midc, Taswade, S. Ward-1, Satara. Umbraj, Taluka Karad, District Satara – 415109. Maharashtra. Pan: Abppp6230R Appellant/ Assessee Respondent / Revenue Assessee By Shri Aditya Ramchandran – Ar Revenue By Shri Akhilesh Srivastva – Addl.Cit(Dr) Date Of Hearing 10/07/2025 Date Of Pronouncement 16/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: The Assessee Has Filed An Appeal Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 10.03.2025 For A.Y.2022-23, Emanating From The Order U/S.143(3) Read With Section 144B Of The Act. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 144BSection 246ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)Section 251(2)

prosecution of the appeal by the assessee. This is amply clear from the Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act which requires the CIT(A) to apply his mind to all the issues which arise from the impugned order before him whether

Welkin Telecom Infra Pvt. Ltd., Kolkata vs. ACIT, Circle 11(1), Kolkata

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 668/KOL/2025[2014-15]Status: DisposedITAT Kolkata16 Jul 2025AY 2014-15

Bench: Shri Duvvuru Rl Reddy(Kz) & Shri Rakesh Mishra

Section 143(3)Section 147Section 148Section 148ASection 250

prosecution of the appeal by the assessee. This is amply clear from the Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act which requires the CIT(A) to apply his mind to all the issues which arise from the impugned order before him whether

Span Construction, Pune vs. I.T.O Wrd-3(3), Pune

In the result, appeal of the assessee is allowed for statistical purpose

ITA 1346/PUN/2025[2017-18]Status: DisposedITAT Pune10 Jul 2025AY 2017-18

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं./Ita No.1346/Pun/2025 िनधा"रण वष" / Assessment Year: 2017-18 Span Construction, V The Income Tax Officer, H1, Flat No.203, S. Ward-3(3), Pune. S.No.123/A/1/1, Vanraji Heights, Rambaug Colony, Near Mit College, Kothrud, Pune – 411038. Maharashtra. Pan: Aaefs2589J Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Smt. Saumya Pandey Jain – Addl.Cit(Dr) Date Of Hearing 07/07/2025 Date Of Pronouncement 10/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: The Assessee Has Filed An Appeal Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 27.03.2025 For A.Y.2017-18, Emanating From The Order U/S.147 R.W.S 144 Read With

Section 144Section 144BSection 147Section 148Section 153CSection 250

prosecution of the appeal by the assessee. This is amply clear from the Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act which requires the CIT(A) to apply his mind to all the issues which arise from the impugned order before him whether

Mobite Technologies Pvt. Ltd., Pune vs. ITO, Ward, 7(1), Pune

In the result, appeal of the assessee is allowed for statistical purpose

ITA 1258/PUN/2025[2021-22]Status: DisposedITAT Pune10 Jul 2025AY 2021-22

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं./Ita No.1258/Pun/2025 िनधा"रण वष" / Assessment Year: 2021-22 Mobite Technologies Private V The Income Tax Officer, Limited, S. Ward-7(1), Pune. A-701, Victoria Garden, Nagar Road, Kalyani Nagar, Pune – 411006. Maharashtra. Pan: Aafcm7197J Appellant/ Assessee Respondent / Revenue Assessee By Shri Abhay Avachat – Ar Revenue By Smt. Shilpa Nc – Addl.Cit(Dr) Date Of Hearing 03/07/2025 Date Of Pronouncement 10/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: The Assessee Has Filed An Appeal Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal)-10, Delhi Passed Under Section 250 Of The Income Tax Act, 1961 Dated 12.02.2025 For A.Y.2021-22, Emanating From The Order U/S.143(1) Of The Act. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Ao Cpc Has Erred In Rejecting Concessional Rate Of Income Tax Of 22% Adopted By Assessee For Calculation Of Tax Liability As Per Itr U/S 115Baa & The Ld. Cit A Erred In Confirming The Same

Section 115Section 115BSection 115JSection 143Section 143(1)Section 234BSection 250

prosecution of the appeal by the assessee. This is amply clear from the Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act which requires the CIT(A) to apply his mind to all the issues which arise from the impugned order before him whether

Shree Rajendra Suri Sah Sakh Santha Myd, Rajgarh, Dhar vs. The ITO, Dhar

ITA 786/IND/2024[2015-16]Status: DisposedITAT Indore09 Jul 2025AY 2015-16

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 143(3)Section 246ASection 253Section 37Section 38(2)Section 80P

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT

Rajbansh Ram, Bhabua vs. ITO Ward- 3(5), Sasaram

In the result, the appeal of the assessee is partly allowed

ITA 351/PAT/2023[2017-18]Status: DisposedITAT Patna04 Jul 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 250Section 68

which is stated to be fit to be reversed on the ground that no valid show cause notice as mandated in section 251(2) of the Act was I.T.A. No.: 351/PAT/2023 Assessment Year: 2017-18 Rajbansh Ram. issued by the NFAC. Further, the entire transactions and the source

Income Tax Officer, Ward-1, Barmer vs. Pushp Raj Bohra, Jalore

The appeal of the revenue is allowed, in the manner discussed as above

ITA 200/JODH/2024[2017-18]Status: DisposedITAT Jodhpur01 Jul 2025AY 2017-18

Bench: Shri Rajpal Yadav, HonʼBle & Dr. Mitha Lal Meena, Hon'Bleito, Ward-1, Barmer. Vs. Pushp Raj Bohra, M-09, Shivaji Nagar, Jalore - 343001. Pan No. Aanpb4456C Assessee By Shri Goutam Chand Baid, C.A. Revenue By Smt. Runi Pal, Cit (D.R.) Date Of Hearing 29.04.2025. Date Of Pronouncement 01.03.2025. Order Per Dr. Mitha Lal Meena, A.M.: The Captioned Appeal Has Been Filed By The Revenue Against The Order Of The Id. National Faceless Appeal Centre [Nfac/Cit(A)], Delhi Dated 08.02.2024 In Respect Of Assessment Year: 2017-18 Where The Department Has Raised Following Grounds: 1. Whether The Id. Cit(A) Is Justified In Facts & Law In Directing To Treat The Income From The Sale Of Immovable Properties As Capital Gains Instead Of Business Income, By Ignoring The Fact That Assesse & His Business Concerns Are Engaged In The Business Of Property & Real Estate Development & Huge Expenses Of Rs. 8.72 Cr. Were Incurred By Assessee On Development Of Projects To Earn Profit. 2. Whether The Id. Cit(A) Has Erred In Law & Facts By Directing The Ao To Treat The Income From The Sale Of Immovable Properties As Income From Capital Gains Instead Of Business Income By Merely Following The Order Of Hon'Ble

Section 142(1)Section 143(3)Section 250Section 54ESection 54F

examine the issue which is not part of the original assessment amount to enhancement of the of the assessment and as per section 251(2) same cannot be done without providing opportunity to the assessee. considering all above factors, it is requested to please issue the requisite order to delete

Virat Solvent Private Limited, Surajpur vs. Deputy Commissioner of Income Tax-1(1), Bilaspur

Appeal of the assessee is partly allowed for statistical purposes, in terms of over aforesaid observations

ITA 384/RPR/2025[2023-24]Status: DisposedITAT Raipur30 Jun 2025AY 2023-24

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 384/Rpr/2025 (िनधा"रण वष" Assessment Year: 2023-24)

For Appellant: Shri R. B. Doshi, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 115BSection 139Section 142Section 143(1)Section 143(1)(a)Section 250

prosecution of the appeal by the assessee. This is amply dear from the Section 251(l)(a) and (b) and Explanation to Section 251(2) of the Act which requires the CIT(A) to apply his mind to at the issues which arise from the impugned order before him whether

Ram Parsad Dav Public School Society, Markanda vs. ITO (Exemptions), Ward, Ambala

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 752/CHANDI/2022[2016-17]Status: DisposedITAT Chandigarh30 Jun 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Vibhor Garg, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 10Section 11(1)(d)Section 12ASection 143(3)Section 2(24)(iia)Section 250(4)Section 250(6)Section 251(2)Section 271(1)(c)

breach to the Provisions of Section 250(6) r.w. Section 250(4), 250(5), 251(l)(a), 251(l)(b) and Explanation to Section 251(2) of the Income Tax Act 1961 pursuant to the case of CIT Vs Prem Kumar Arjundas Luthra (HUF) (2017) 154 DTR302(Bom). 2. Because ... legal infirmities, alleging violations of Sections 250(4), 250(5), 250(6), 251(1)(a), 251(1)(b), and the Explanation to Section 251(2) of the Income Tax Act, 1961. It was submitted that the order lacks proper reasoning, thereby contravening the principles laid down in CIT v. Prem

Bhandari Construction, Bilaspur vs. ITO Ward-1(1), Bilaspur

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

ITA 331/RPR/2025[2017-18]Status: DisposedITAT Raipur27 Jun 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.331/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Bhandari Construction Nutan Chowk, Seepat Road, Sarkanda, Bilaspur (C.G.)-495 001 Pan: Aajfb9702B .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 147Section 148Section 148ASection 151Section 69

आयकर अपील"य अ"धकरण "यायपीठ “एक-सद"य” मामला रायपुर म" IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH

Myvishwa Technologies Pvt. Ltd., Pune vs. Dycit Circle-7, Pune

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 942/PUN/2025[2018-19]Status: DisposedITAT Pune27 Jun 2025AY 2018-19

Bench: Ms.Astha Chandra, Judicialmember & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.942/Pun/2025 िनधा"रण वष" / Assessment Year: 2018-19 Myvishwa Technologies Pvt. V The Dy.Commissioner Of Ltd., S Income Tax, Circle-7, Flat No.16, Sawali, Pan Mala, Pune. Off Sinhgad Road, Pune- 411030. Maharashtra. Pan: Aafcm9656E Appellant/ Assessee Respondent / Revenue Assessee By Shri Mahavir Jain – Ar Revenue By Shri Rajesh Haladkar – Addl.Cit(Dr) Date Of Hearing 26/06/2025 Date Of Pronouncement 27/06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961, Dated 07.02.2025 Emanating From The Assessment Order Passed U/S.143(3) Of The Income Tax Act, 1961, For A.Y.2018-19 Dated 24.02.2021. The Assessee Has Raised Following Grounds Of Appeal :

Section 143(3)Section 250Section 32Section 32(1)

prosecution of the appeal by the assessee. This is amply clear from the Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act which requires the CIT(A) to apply his mind to all the issues which arise from the impugned order before him whether

Ellapu Narasamma L/R of Late Ellapu Appa Rao, Visakhapatnam vs. Income Tax Officer, Ward-2(3), Visakhapatnam

ITA 414/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam26 Jun 2025AY 2017-18

Bench: Us:

Section 133(6)Section 142(1)Section 144Section 69A

आयकर अपीलीय अधिकरण, विशाखापटणम पीठ में IN THE INCOME TAX APPELLATE TRIBUNAL Visakhapatnam Bench श्री रिीश सूद, माननीय न्याययक सदस्य

Deputy Commissioner of Income Tax. Circle-Agartala, Agartala vs. Shri Satyajit Saha, Agartala

ITA 190/GTY/2019[2014-15]Status: DisposedITAT Guwahati25 Jun 2025AY 2014-15

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 133(6)Section 250Section 68Section 69

rate of 0.78% amounts to enhancement of income, we find that the Ld. CIT(A) has not followed the procedure laid down in section 251(2) of the Act and hence we remand this matter back on the specific issue of following the mandate of section 251(2

Mintu Rani, Patna vs. Assessement Unit, Income Tax Department, Delhi

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 16/PAT/2025[2015-16]Status: DisposedITAT Patna25 Jun 2025AY 2015-16

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 147Section 250

prosecution of the appeal by the assessee. This is amply clear from the Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act which requires the CIT(A) to apply his mind to all the issues which arise from the impugned order before him whether