← All Phrases

“Section 251(1)”

Section References (mined)Section 251Section 251(1)929 judgments

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

Leading authorities on Section 251(1)

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.

CIT v. Shapoorji Pallonji Mistry
44 ITR 891 · 1962 · Supreme Court
278
citing judgments

The Commissioner of Income-tax (Appeals) cannot enhance an assessment by introducing a new source of income or by changing the head of income during appellate proceedings.

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. Sardari Lal & Co.
251 ITR 864 · 2001 · High Court
240
citing judgments

An appellate authority cannot introduce a new source of income that was not considered by the Assessing Officer; taxability of new sources should be addressed through reassessment provisions like Section 147/148 or revision under Section 263.

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.

Smt. Prabhavati S. Shah v. CIT
231 ITR 1 · 1998 · High Court
186
citing judgments

The first appellate authority must admit additional evidence if it is necessary for determining the true state of affairs and preventing undue hardship or a failure of justice, even without a specific request and particularly when the case falls under Rule 46A(1)(c).

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.

Judgments citing Section 251(1)

Assystem Engineering Amd Operation Services, France vs. Dy. Commissioner of Income-Tax, Circle-1(1)(1), International Taxation, New Delhi

In the result the appeal of the assessee is dismissed

ITA 3392/DEL/2025[2018-19]Status: DisposedITAT Delhi17 Oct 2025AY 2018-19

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2018-19 Assystem Engineering & Vs. Dy. Commissioner Of Operation Services Income Tax Circle-1(1) (1) Tour Egee 9-11 Allee De International Taxation Larche Courbevoie France- 92400 Pan No. Aajca2418E (Appellant) (Respondent)

Section 143(1)Section 154(3)Section 234Section 234DSection 250(6)Section 251(1)(a)

against the provisions enshrined vide section 250(6) of the Act. 3. That in the light of the statutory embargo created vide section 251(1)(a) of the Act the action of the Ld. CIT(A) of remanding the matter and directing the Assessing Officer to decide afresh

Aryavart Bank, Lucknow vs. Dy. Commissioner of Income Tax, Range-1, Lucknow

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

ITA 800/LKW/2024[2012-13]Status: DisposedITAT Lucknow16 Oct 2025AY 2012-13

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y. 2012-13 Uttar Pradesh Gramin Bank, Vs. Dcit-Range 1, (Successor To Erstwhile Allahabad U.P. Lucknow Gramin Bank), Head Office, 2Nd & 3Rd Floor, Nbcc Commercial Complex, Vardan Khand, Gomti Nagar Extension, Lucknow Pan: Aaaju0568R (Appellant) (Respondent) Assessee By: Sh. C. Naresh, Fca Revenue By: Sh. R.K. Agarwal, Cit Dr Date Of Hearing: 28.07.2025 Date Of Pronouncement: 16.10.2025 O R D E R Per Nikhil Choudhary, A.M.: [ This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit(A) Setting Aside The Orders Of The Ld. Assessing Officer That Were Passed Under Section 147 R.W.S. 144 On 30.12.2019. The Grounds Of Appeal Are As Under:- “1. On The Facts & In The Circumstances Of The Case & In Law, The Id. Cit(A), Nfac Erred In Not Granting Opportunity To The Appellant Bank To Present The Case Through Video Conferencing As Specified Under Faceless Appeal Scheme, 2020 Provided U/S. 250(68) Of The Income Tax Act, 1961 ("The Act"). The Hon'Ble Cit(A) Be Directed To Grant Personal Hearing Through Video Conferencing In The Interest Of Justice. Without Prejudice To The Above 2. On The Facts & In The Circumstances Of The Case & In Law, The Id. Cit(A) Erred In Invoking The Provisions Of Proviso To Section 251(1)(A) & Setting Aside The Order To Ao Without Appreciating That The Order Was Not Passed U/S 144. 3. On The Facts & In The Circumstances Of The Case & In Law, The Id. Cit(A) Failed To Appreciate That The Din Was Issued In The Name Of Non-Existing Entity & Hence The Order Passed Is Invalid. Without Prejudice To The Above

For Appellant: Sh. C. Naresh, FCAFor Respondent: Sh. R.K. Agarwal, CIT DR
Section 144Section 147Section 148Section 234ASection 244ASection 250(68)Section 251(1)(a)Section 36(1)(viia)Section 80P

facts and in the circumstances of the case and in law, the Id. CIT(A) erred in invoking the provisions of proviso to section 251(1)(a) and setting aside the order to AO without appreciating that the order was not passed u/s 144. 3. On the facts ... arguing on behalf of the assessee submitted that the ld. CIT(A) had erred in invoking the provisions of the proviso to section 251 (1)(a) and setting aside the order to the AO, without appreciating that the order was not passed under section 144. He had failed to decide

Bhagwant Kaur, Mohali vs. Income Tax Officer, Ward-6(1), Chandigarh

In the result, appeal of the Assessee is dismissed

ITA 122/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh16 Oct 2025AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal. C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 142(1)Section 144Section 148Section 148rSection 251(1)(a)Section 69

required further verification and examination of the facts and documents furnished by the assessee. The CIT(A) invoked the newly inserted proviso to section 251(1)(a) of the Act (effective from 01.10.2024), empowering the appellate authority to set aside an assessment made under section 144 and remand the case ... sources and that no reasonable opportunity was provided to furnish supporting evidence. The Ld. CIT(A), by invoking the newly inserted proviso to section 251(1)(a), has rightly set aside the assessment and directed the Assessing Officer to make a fresh assessment. In the interest of justice, we find

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1296/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2017-18

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

rightly restored the matter to the Assessing Officer for fresh adjudication on merits. Such direction is consistent with section 250(4) and section 251(1)(a) of the Act and ensures proper examination of the assessee’s claims while preserving the jurisdictional validity of the reassessment. 7.22 In view

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1295/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2016-17

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

rightly restored the matter to the Assessing Officer for fresh adjudication on merits. Such direction is consistent with section 250(4) and section 251(1)(a) of the Act and ensures proper examination of the assessee’s claims while preserving the jurisdictional validity of the reassessment. 7.22 In view

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1294/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2015-16

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

rightly restored the matter to the Assessing Officer for fresh adjudication on merits. Such direction is consistent with section 250(4) and section 251(1)(a) of the Act and ensures proper examination of the assessee’s claims while preserving the jurisdictional validity of the reassessment. 7.22 In view

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward 2(1)(1), Ahmedabad

ITA 1293/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2014-15

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

rightly restored the matter to the Assessing Officer for fresh adjudication on merits. Such direction is consistent with section 250(4) and section 251(1)(a) of the Act and ensures proper examination of the assessee’s claims while preserving the jurisdictional validity of the reassessment. 7.22 In view

Yakin Jayantilal Shah, Ahmedabad vs. ITO, Ward2(1)(1), Ahmedabad

ITA 1292/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2013-14

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: Shri Veerabadram Vislavath, Sr.DR
Section 139(1)Section 144BSection 147Section 250

rightly restored the matter to the Assessing Officer for fresh adjudication on merits. Such direction is consistent with section 250(4) and section 251(1)(a) of the Act and ensures proper examination of the assessee’s claims while preserving the jurisdictional validity of the reassessment. 7.22 In view

Mukul Hasteer, Karnal vs. ITO Ward-1, Karnal

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

ITA 96/DEL/2025[2018-19]Status: DisposedITAT Delhi15 Oct 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 234A

appeal in writing with well-reasoned order on each point of determination arisen for his consideration. It is evident from the perusal of section 251(1)(a), 251(1)(b) and Explanation of section 251(2) of the Act that the CIT(A) is required to apply his/her mind

Gulshan Kumar, Gurgaon vs. ITO Ward-1(3), Gurgaon

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

ITA 2242/DEL/2025[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 194HSection 250Section 40Section 44ASection 69A

appeal in writing with well-reasoned order on each point of determination arisen for his consideration. It is evident from the perusal of section 251(1)(a), 251(1)(b) and Explanation of section 251(2) of the Act that the CIT(A) is required to apply his/her mind

Cherukuri Veeraju, Rajahmundry vs. The Deputy Commissioner of Income Tax, Circle-1, Rajahmundry

ITA 465/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam13 Oct 2025AY 2017-18

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.465/Viz/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Cherukuri Veeraju, Vs. Deputy Commissioner Rajahmundry. Of Income Tax, Pan:Abxpc6760H Circle-1, Rajahmundry. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 08/10/2025 घोषणा की तारीख/Date Of 13/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Center (Nfac), Delhi, Dated 27/05/2025, Which In Turn Arises From The Order Passed By The Additional/Joint Commissioner Of Income Tax, National Faceless Assessment Centre (Nafac), Delhi Under Section 271D Of The 2 Cherukuri Veeraju Vs. Dcit

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(2)Section 143(3)Section 271D

Premkumar Arjundas Luthra (HUF) (2017) 297 CTR 614 (Bom). In the aforementioned case, the Hon'ble High Court by referring to Section 251(1)(a) and (b) and “Explanation” to Sec. 251(2) of the Act, had observed that the CIT(A) is required to apply his mind

Mohammed Rauf Farook Khan, Thane vs. Income Tax Officer Ward 1(1), Thane

In the result, the appeal is allowed for statistical

ITA 4015/MUM/2025[2016-17]Status: DisposedITAT Mumbai13 Oct 2025AY 2016-17

Bench: Shri Pawan Singh & Shri Prabhash Shankar

For Appellant: Shri Madhukeshwar Hegde, CAFor Respondent: Shri Annavaran Kasuri,(Sr. AR)
Section 142(1)Section 143(1)Section 147Section 148Section 149Section 149(1)(b)Section 50CSection 56(2)(x)

make further inquiry and report the result of the same to him as per section 250(4) of the Act. Section 251(1)(a) and (b) of the Act provide Page 6 ITA No. 4015/Mum/2025 A.Y. 2016-17 Mohammed Rauf Farook Khan that while disposing of appeal

Byas Prasad Verma, Kushinagar vs. Income Tax Officer, Ward - 2(4), Kushinagar

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

ITA 2/VNS/2024[2012-2013]Status: DisposedITAT Varanasi10 Oct 2025AY 2012-2013

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2012-13 Byas Prasad Verma V. The Income Tax Officer Vill. Dhaurahara Ward 2(4) Nadwa Bishunpur Kushinagar Fazilnagar, Kushinagar (U.P) Tan/Pan:Amupv6031E (Appellant) (Respondent) Appellant By: None Respondent By: Smt Amandeep Kaur, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 26.07.2023, Passed By The National Faceless Appeal Centre (Nfac), Delhi For Assessment Year 2012-13. 2.0 The Brief Facts Of The Case Are That The Assessee Had Not Filed His Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Made Cash Deposits To The Tune Of Rs.16,45,000/- In His Saving Bank Account. In Order To Examine These Facts, The Assessing Officer (Ao) Reopened The Case Of The Assessee Under Section 147 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) After Issuing Notice Under Section 148 Of The Act. Thereafter, The Ao Issued Statutory Notices To The Assessee, Requiring The Assessee To Furnish The Source Of Cash

For Appellant: NoneFor Respondent: Smt Amandeep Kaur, D.R
Section 144Section 147Section 148Section 250Section 250(6)Section 251(1)(a)Section 251(2)Section 69A

income of appellant without going into the roots of transactions. 6. BECAUSE the learned CIT(A) NFAC has failed to appreciate that that Section 251(1)(a) and (b) and Explanation to Section 251(2) of the I.T. Act requires the CIT(A) to apply his own mind

Princess Infra & Development LLP, Kota vs. ACIT-Central Circle-Kota, Kota

In the result, both the appeals of the assesseeare allowed for statistical purposes as indicate hereinabove

ITA 859/JPR/2025[2018-19]Status: DisposedITAT Jaipur10 Oct 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Saurav Harsh, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 144Section 153B(1)(b)Section 153CSection 56(2)(X)Section 68

Assessing Officer passed Ex-parte assessment vide order dated 27.12.2019 under section 144 of the Act hence the aforesaid proviso of section 251(1)(a) of the Act is applicable in the instant case also. We are enclosing herewith an order passed by a CIT (Appeals) NFAC following the similar ... Assessing Officer passed Ex-parte assessment vide order dated 27.12.2019 under section 144 of the Act. hence the aforesaid proviso of section 251(1)(a) of the Act is applicable in the instant case also. We are enclosing herewith an order passed by a CIT(Appeals), NFACfollowingthe similar provision

Princess Infra & Development LLP, Kota vs. ACIT-Central Circle-Kota, Kota

In the result, both the appeals of the assesseeare allowed for statistical purposes as indicate hereinabove

ITA 858/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Saurav Harsh, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 144Section 153B(1)(b)Section 153CSection 56(2)(X)Section 68

Assessing Officer passed Ex-parte assessment vide order dated 27.12.2019 under section 144 of the Act hence the aforesaid proviso of section 251(1)(a) of the Act is applicable in the instant case also. We are enclosing herewith an order passed by a CIT (Appeals) NFAC following the similar ... Assessing Officer passed Ex-parte assessment vide order dated 27.12.2019 under section 144 of the Act. hence the aforesaid proviso of section 251(1)(a) of the Act is applicable in the instant case also. We are enclosing herewith an order passed by a CIT(Appeals), NFACfollowingthe similar provision

Shyamprasad Reddy Gaddam, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 196/HYD/2024[2014-15]Status: DisposedITAT Hyderabad10 Oct 2025AY 2014-15

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 196/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2014-15) Shyamprasad Reddy Vs. Dcit, Gaddam, Central Circle-3(3), Hyderabad. Hyderabad. Pan: Aetpg9117P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri P. Murali Mohan Rao, Ca राज" व "ारा/Revenue By: Sri Gurpreet Singh, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/10/2025 घोषणा की तारीख/Date Of 10/10/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals)- 11, Hyderabad, Dated 02/02/2004, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 144 R.W.S 153A Of The Income Tax Act, 1961 (For Short, “Act”), Dated 12/12/2019 For The Assessment Year 2014-15. 2 Shyamprasad Reddy Gaddam Vs. Dcit

For Appellant: Sri P. Murali Mohan Rao, CAFor Respondent: Sri Gurpreet Singh, Sr. AR
Section 132Section 132(4)Section 144Section 153ASection 250Section 68Section 69Section 69A

divested of his jurisdiction to introduce a new source of addition while exercising the power of enhancement vested with him under Section 251(1) of the Act. Apart from that, the Ld. AR had relied upon the orders of the coordinate benches of the Tribunal viz., (i) Sekhar Jayalakshmi Doshi ... said purported course of action during the appellate proceedings. 20. We are of a firm conviction that though, the CIT(A), as per section 251(1)(a) of the Act is vested with the jurisdiction to confirm, reduce, enhance or annul the assessment, but in a case where he seeks

Bhawani Developers, Lucknow vs. Income Tax Officer-4(1), Lucknow-New

Appeal is disposed of in accordance with the aforesaid

ITA 253/LKW/2025[2018-19]Status: DisposedITAT Lucknow09 Oct 2025AY 2018-19

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 115BSection 133(6)Section 142(1)Section 144BSection 147Section 68

well. In this context, it will be useful to refer to relevant provisions of law under section 250(6), section 250(7) and section 251(1) of I. T. Act, which are reproduced below for the ease of reference: Section-250 (6) The order of the [Joint Commissioner (Appeals ... communicate the order passed by him to the assessee and to the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. Section 251 (1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers— (a) in an appeal against an order of assessment

Ojasvi Media Matrix Private Limited, Indore vs. AO, NFAC Delhi

In the result, appeal filed by the Assessee stands allowed for statistical purposes

ITA 5210/MUM/2025[2022-23]Status: DisposedITAT Mumbai09 Oct 2025AY 2022-23

Bench: Shri Narender Kumar Choudhryojasvi Media Matrix Pvt. Assessing Officer, Nfac, Ltd., 852, Sudama Nagar, Delhi. Vs. Opp. Jain Mandir, Indore (Mp) Pan: Aabco 1930 D (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri Pitamber Kumar, Ld. Sr.D.R
Section 143(3)Section 250Section 251Section 251(1)(a)

Premkumar Arjundas Luthra (HUF) (2017) 297 CTR 614 (Bom.) wherein it has been held as under:- “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

Runa Vishal Shah, Mumbai vs. Income Tax Officer Ward 22(3)(2), Mumbai

In the result, appeal filed by the Assessee stands allowed for statistical purposes

ITA 3792/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Oct 2025AY 2013-14

Bench: Shri Narender Kumar Choudhryruna Vishal Shah, Block Ito, Ward-22(3)(2), No.3, Veer Building, Mumbai. Tagore Road, Santacruz Vs. (W), Mumbai. Pan: Bdcps 8211 D (Appellant) (Respondent)

For Appellant: Shri Shashank Mehta, Ld. A.RFor Respondent: Shri Pushkaraj Bhangepatil, Ld. Sr.DR
Section 143(3)Section 250Section 251Section 251(1)(a)Section 68Section 69C

Premkumar Arjundas Luthra (HUF) (2017) 297 CTR 614 (Bom.) wherein it has been held as under: - “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

Inner Chef Private Ltd, Gurugram vs. ACIT, Circle-4(1), Gurgaon

In the result, appeal of assessee in ITA No

ITA 2184/DEL/2025[2017-18]Status: DisposedITAT Delhi08 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Sameer Kapoor, CAFor Respondent: Shri Jitender Singh, CIT-DR
Section 115BSection 143(3)Section 144Section 251(1)(a)Section 40Section 40aSection 68

that the AO made the assessment u/s 143(3) of the Act and hence the CIT(A) exceeded his jurisdiction under proviso to section 251(1)(a) in referring the issue of addition u/s 68 back to the AO for verification. We also find that