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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)

Nazir Ahmad Bhat, Anantnag vs. ITO, Anantnag

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 273/ASR/2025[2011-12]Status: HeardITAT Amritsar19 Dec 2025AY 2011-12

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Vaseem Ahmad, C. A
Section 133(6)Section 142(1)Section 144Section 148Section 250Section 251(2)

rival counsels and we find that the Ld CIT ( A ) has taken recourse to enhancement vide notice issued as per provisions of section 251(2) of the Act 61 for both the years due to reasons contained in the respective SCN , to which proper explanation with supporting documentary evidences

Jai Hind Souharda Pattin Sahakari Niyamit, Belagavi vs. Income Tax Officer, Ward - 1(3), Belagavi

The appeal is allowed for statistical purposes

ITA 168/PAN/2025[2012-13]Status: DisposedITAT Panaji16 Dec 2025AY 2012-13

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2012-13 Jai Hind Souharda Sahakari Sangh Niyamit, Bazar Road, Tal.: Hukkeri, Belgavi-591309 Pan:Aaajj0226F . . . . . . . Appellant

For Appellant: Mr Pramod Vaidya [‘Ld. AR’]For Respondent: Ms Rijjula Uniyal[‘Ld. DR’]
Section 143(1)Section 143(3)Section 250Section 250(6)Section 251(1)(a)Section 251(2)Section 253(1)Section 80P

view of prescription of Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act was required to apply his mind to all the issues which arise from the impugned order before him whether or not the same has been raised in form

Anwar Husain Mehboob Shaikh, Jalgaon vs. Income Tax Officer, Jalgaon

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

ITA 2561/PUN/2025[2018-2019]Status: DisposedITAT Pune12 Dec 2025AY 2018-2019

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2561/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 Anwar Husain Mehboob V The Income Tax Officer, Shaikh, S Jalgaon. H. No.K 258/I Railway North Area, Bhusawal, Jalgaon – 425201. Pan: Bodps9742F Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Sandeep Sathe - Dr Date Of Hearing 10/12/2025 Date Of Pronouncement 12/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2018-19 Dated 21.08.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Of The Act, Dated 31.01.2024. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144BSection 147Section 148Section 151ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)

appeal by the assessee. This is amply ITA No.2561/PUN/2025 [A] 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

The Merchants Co-Op Bank Ltd. ( in Liquidation), Dhule vs. The ITO, Ward- -1, Dhule

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

ITA 1927/PUN/2025[2018-19]Status: DisposedITAT Pune12 Dec 2025AY 2018-19

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1927/Pun/2025 निर्धारण वषा / Assessment Year: 2018-19 The Merchants Co-Op Bank V The Income Tax Officer, Ltd., (In Liquidation), S. Ward-1, Dhule. Cs No.2111, Lane No.6, Near Old Amnalner Stand, Nagarpatti, Dhule-424001. Pan: Aaabt0123H Appellant/ Assessee Respondent / Revenue Assessee By Shri Kishor B Phadke Revenue By Smt Indira R. Adakil-Addl.Cit(Dr) Date Of Hearing 02/12/2025 Date Of Pronouncement 12/12/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018-19, Dated 11.03.2025 Emanating From Assessment Order 147 R.W.S 144 Of The Income Tax Act, 1961 Dated 29.03.2023. The Assessee Has Raised Following Grounds Of Appeal : “1. Appellant Contends That The Learned Cit(A), Nfac Ought To Have

Section 147Section 148Section 151ASection 21(2)Section 250Section 80P

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

Katrapally Venumadhav, Warangal vs. Income Tax Officer, Ward-4(1), Hyderabad

ITA 1396/HYD/2025[2018-19]Status: DisposedITAT Hyderabad12 Dec 2025AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 151Section 270ASection 282

आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad "ी रवीश सूद, माननीय

Katrapally Venumadhav, Warangal vs. Income Tax Officer, Ward-4(1), Hyderabad

ITA 1395/HYD/2025[2018-19]Status: DisposedITAT Hyderabad12 Dec 2025AY 2018-19

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 147Section 148Section 148ASection 151Section 270ASection 282

आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad "ी रवीश सूद, माननीय

National Institute of Construction Management and Research, Mumbai vs. DCIT(Exemptions), Circle-2, Mumbai

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

ITA 5987/MUM/2025[2023-24]Status: DisposedITAT Mumbai09 Dec 2025AY 2023-24

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailnational Institute Of Construction Management & Research, Walchand Centre, Walchand Terraces, Tardeo Road, Ac Market ............... Appellant Mumbai – 400034 Pan : Aaatn1348J V/S Deputy Commissioner Of Income Tax (Exemptions), Circle - 2, ……………… Respondent Cumbala Hill, Telephone Exchange, Peddar Road, Mumbai - 400026

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri Solgy Jose T. Kottaram, CIT-DR
Section 11(1)(a)Section 11(5)Section 143(3)Section 144B(1)(xii)Section 250Section 250(4)Section 250(6)Section 251(1)(a)Section 251(2)

erred in dismissing the appeal for want of prosecution when Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act categorically require the CIT(A) to apply his mind to all the issues which arise from the impugned order before him whether

Canara Bank (E-Syndicate) Bandra West II Branch, Mumbai vs. Income Tax Officer, TDS, Mumbai

In the result, both the appeal under consideration are allowed

ITA 6312/MUM/2025[2016-17]Status: DisposedITAT Mumbai03 Dec 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Ms. Renu Jauhri

For Appellant: Shri S. Ananthan & Mrs. Lalitha Rameswaran, Ld. ARsFor Respondent: Shri Virabhadra S. Mahajan, Ld. Sr. D.R
Section 133Section 201(1)Section 250

Bombay), wherein it has been held as under :- “Section 251(1)(a) and (b), along with the explanation in Section 251(2) of the Act, mandates that the CIT(A) must apply their mind to all issues arising from the order being appealed, regardless of whether the appellant specifically raised

Canara Bank (E-Syndicate) Bandra West II Branch, Mumbai vs. Income Tax Officer, TDS, Mumbai

In the result, both the appeal under consideration are allowed

ITA 6310/MUM/2025[2014-15]Status: DisposedITAT Mumbai03 Dec 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Ms. Renu Jauhri

For Appellant: Shri S. Ananthan & Mrs. Lalitha Rameswaran, Ld. ARsFor Respondent: Shri Virabhadra S. Mahajan, Ld. Sr. D.R
Section 133Section 201(1)Section 250

Bombay), wherein it has been held as under :- “Section 251(1)(a) and (b), along with the explanation in Section 251(2) of the Act, mandates that the CIT(A) must apply their mind to all issues arising from the order being appealed, regardless of whether the appellant specifically raised

Federation of European Business in India, Delhi vs. CIT(Exemption), Delhi

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

ITA 2446/DEL/2025[-]Status: DisposedITAT Delhi03 Dec 2025

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishrafederation Of European Commissioner Of Income Business In India, Tax (Exemption), Aiwan-E-Ghalib Complex, Vs. E-2, Civic Centre, Mata Sundari Lane, Minto Road, Minto Road, New Delhi-110002 New Delhi-110002 Pan: Aafcf5934N (Appellant) (Respondent) Appellant By Sh. Amol Sinha, Advocate Sh. Ankit Kumar, Advocate Respondent By Sh. Jitender Singh, Cit-Dr Date Of Hearing 15/10/2025 Date Of Pronouncement 03/12/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal Filed By The Assessee Is Directed Against The Order Dated 06.03.2025 Of The Commissioner Of Income Tax (Exemption), New Delhi [‘Cit(E)’].

Section 12ASection 12A(1)(ac)Section 2(15)Section 8

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI

Our Vision Entertainment LLP, Mumbai vs. Assistant Commissioner of Income Tax Circle 24(1), Mumbai

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

ITA 4724/MUM/2025[2016-17]Status: DisposedITAT Mumbai02 Dec 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Ms. Renu Jauhriassessment Year: 2016-17 M/S. Our Vision Entertainment Income Tax Officer Llp, 15(1)(1), Office No.304, Twin Complex B 103, Aayakar Bhavan, Vs. Block, Andheri East Mumbai - 400020 Opp Marol Fire Brigade Maharashtra - 400 059 Pan: Aaefo8646C (Appellant) (Respondent)

Section 144Section 250

Bombay), wherein it has been held as under: - “Section 251(1)(a) and (b), along with the explanation in Section 251(2) of the Act, mandates that the CIT(A) must apply their mind to all issues arising from the order being appealed, regardless of whether the appellant specifically raised

Shrimadurjit Seva Kendra, Pune vs. The ITO, Ward 8(3), Pune

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

ITA 2276/PUN/2025[2013-2014]Status: DisposedITAT Pune28 Nov 2025AY 2013-2014

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2276/Pun/2025 निर्धारण वषा / Assessment Year: 2013-14 Shrimadurjit Seva Kendra, V The Income Tax Officer, S.No.117/1, Chowisawdi, S. Ward-8(3), Pune. Haveli, Pune – 412105. Pan: Absfs4340L Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Amit Bobde –Cit(Dr) Date Of Hearing 19/11/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Appeal Has Been Filed By The Assessee Against The Order Of Ld.Additional/Joint Commisioner Of Income Tax(Appeal), Panaji Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 Dated 31.07.2025. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Addl./Jt.Cit(A), Panaji Erred In Law & On Facts In Dismissing Appellant'S Appeal Without Granting Sufficient Opportunity Of Being Heard. Appellant Assures To Make All The Compliances Before The

Section 200ASection 220(2)Section 234ESection 246ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)

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 4 issues which arise from the impugned order before

Sachin Prakashchand Aanchaliya, Aurangabad vs. ITO Ward 1 (1), Aurangabad

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

ITA 2345/PUN/2025[2013-2014]Status: DisposedITAT Pune27 Nov 2025AY 2013-2014

Bench: Or At The Time Of Hearing Of The Appeal.”

Section 144Section 144BSection 147Section 250Section 250(4)

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

Shahbaz Mohammed Shafeeque, Malegaon vs. Income Tax Officer, Ward - 1, Malegaon

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

ITA 2291/PUN/2025[2015 - 16]Status: DisposedITAT Pune20 Nov 2025

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2291/Pun/2025 निर्धारण वषा / Assessment Year: 2015-16 Shahbaz Mohammed V The Income Tax Officer, Shafeeque, S. Ward-1, Malegaon. House No.904, Lane No.2, Malegaon City S.O., Malegaon, Nashik, Malegaon – 423203. Maharashtra. Pan: Cfppm6844A Appellant/ Assessee Respondent / Revenue Assessee By Shri Sanket Joshi (Virtual) Revenue By Smt Saumya Pandey Jain-Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 20/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Appeal Has Been Filed By The Assessee Against The Order Of Ld.Commisioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2015-16 Dated 28.02.2025. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144Section 147Section 148Section 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

Sachin Shantilal Khiwansara, Beed vs. Income Tax Officer, Aurangabad

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

ITA 2288/PUN/2025[2016-17]Status: DisposedITAT Pune20 Nov 2025AY 2016-17

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2288/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Sachin Shantilal Khiwansara, V The Income Tax Officer, Main Road, Shirur Kasar, S. Ward-1(5), Aurangabad. Shirur So., Beed, Beed – 413249. Pan: Bytpk1339N Appellant/ Assessee Respondent / Revenue Assessee By Shri Saurabh D.Khivansara Revenue By Smt Saumya Pandey Jain-Addl.Cit Date Of Hearing 20/11/2025 Date Of Pronouncement 20/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Appeal Has Been Filed By The Assessee Against The Order Of Ld.Commisioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2016-17 Dated 17.07.2025. The Assessee Has Raised The Following Grounds Of Appeal : “1. That On Facts & In Law, The Ex-Parte Order Of Ld. Cit Appeals, Nfac Is Opposed To Law & Against The Principles Of Natural Justice & Accordingly The Impugned Appellate Order Is Liable To Be Set Aside.

Section 144Section 147Section 148Section 250Section 250(6)

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

Anjaneyulu Reddy Ammireddy, Vinukonda vs. Income Tax Officer, Ward-1, Narasaraopet

ITA 542/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam19 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.542/Viz/2025 (निर्धारण वर्ा/Assessment Year:2018-19) Vs. Anjaneyulu Reddy Ammireddy, Income Tax Officer, Vinukonda. Ward-1, Pan: Aelpa3332C Narasaraopet. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri Gvn Hari, Advocate रधजस्‍व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of Hearing: 06/11/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 25/07/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 29/02/2024. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal:

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 142(1)Section 143(2)Section 147Section 148Section 148ASection 151Section 151ASection 69

आयकर अपीलीय अधिकरण, धिशाखापटणम पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Visakhapatnam Bench, Visakhapatnam Before Shri Ravish Sood, Judicial Member

S R Constructions, Bangalore vs. DCIT, Central Circle-2(2), Bengaluru

ITA 637/BANG/2025[2016-17]Status: DisposedITAT Bangalore18 Nov 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Shri. Muthu Shankar,CIT(DR)(ITAT), Bangalore
Section 40A

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. SOUNDARARAJAN K

S R Constructions, Bangalore vs. DCIT, Central Circle-2(2), Bangalore

ITA 636/BANG/2025[2015-16]Status: DisposedITAT Bangalore18 Nov 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

Section 40A

IN THE INCOME TAX APPELLATE TRIBUNAL "B" BENCH : BANGALORE BEFORE SHRI. LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI. SOUNDARARAJAN K

New Mangalore Port Road Company Limited, New Delhi vs. DCIT, Circle-16(1), Delhi

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 1053/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Nov 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishraita No.1053/Del/2025, A.Y. 2015-16 New Mangalore Port Road Deputy Commissioner Of Company Limited, Income Tax, Circle-16(1), D-21, Corporate Park, Vs. C. R. Building, I P Estate, Sector-21, Dwarka, New Delhi New Delhi Pan: Aabcn9106E (Appellant) (Respondent) Appellant By Ms. Khushboo Singhal, Ca Respondent By Ms. Amisha S. Gupt, Cit(Dr) Date Of Hearing 21/08/2025 Date Of Pronouncement 17/11/2025 Order Per Avdhesh Kumar Mishra, Am This Appeal For Assessment Year (‘Ay’) 2015-16 Filed By The Assessee Is Directed Against The Order Dated 15.09.2022 Of The Commissioner Of Income Tax (Appeals), Nfac, New Delhi [‘Cit(A)’].

Section 271(1)(c)Section 32Section 36(1)(iii)

adjudicated each ground of appeal raised before him though in view of section 251(1)(a), 251(1)(b) and Explanation of section 251(2) of the Act, the Ld. CIT(A) is required to apply his/her mind to all issues which arise from the impugned order before him/her, whether ... read with sections 250(4), 250(5), 251(1)(a), 251(1)(b) of the Act and Explanation of section 251(2) of the Act, the Ld. CIT(A) is not empowered to New Mangalore Port Road Company Ltd. dismiss the appeal summarily. Facts of this case is quite different

Simrah Builders, Aligarh vs. DCIT4(1)(1) Aligarh, Aligarh

In the result, the assessee’s appeal is allowed in the above terms

ITA 151/AGR/2025[2018-19]Status: DisposedITAT Agra14 Nov 2025AY 2018-19

Bench: : Shri M. Balaganesh & Shri Sunil Kumar Singhassessment Year: 2018-19

Section 144ASection 147Section 148Section 151ASection 250Section 251Section 68

assessee. As regards the 4 | P a g e exercise of enhancement powers by ld. CIT(Appeals), the relevant part of section 251(2) of the Act reads as under : “251. (1) xxxxxx xxxxxx xxxxxx xxxxxx (2) The Joint Commissioner (Appeals) or the Commissioner (Appeals), as the case ... such powers conferred in ld. CIT(Appeals) could not be exercised by the Commissioner without complying with the mandatory requirement of section 251(2) of the Act. Failure to afford a reasonable opportunity of showing cause against such enhancement made by the learned CIT(A) makes the impugned order