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“Section 250(2)”

Section References (mined)Section 250Section 250(2)57 judgments

The decision most relied on for Section 250(2) is CIT v. Vegetable Products Ltd. (88 ITR 192), cited in 2,664 judgments on BharatTax.

Leading authorities on Section 250(2)

CIT v. Vegetable Products Ltd.
88 ITR 192 · 1973 · Supreme Court
2,664
citing judgments

When two equally plausible interpretations of a taxing provision are possible, or when conflicting views exist from non-jurisdictional High Courts, the interpretation that favors the assessee must be adopted.

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

Fatehraj Singhvi v. UOI
73 Taxmann.com 252 · 2016 · High Court
1,778
citing judgments

Late fees under section 234E are not applicable for periods prior to June 1, 2015, as the amendment to section 200A inserting clause (c) was effective from that date.

Maxopp Investment Ltd. v. CIT
402 ITR 640 · 2018 · Supreme Court
1,596
citing judgments

Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.

Cheminvest Ltd. v. CIT
378 ITR 33 · 2015 · High Court
1,569
citing judgments

A disallowance under Section 14A of the Income-tax Act, 1961, for expenditure incurred in relation to exempt income cannot be made if the assessee has not earned any exempt income during the relevant previous year.

CIT v. Vatika Township Pvt. Ltd.
367 ITR 466 · 2014 · Supreme Court
1,558
citing judgments

Taxing statutes are presumed to operate prospectively unless a clear contrary intention for retrospective application is evident. The law applicable for determining tax liability is that which stands on the first day of the assessment year, following the principle that law looks forward, not backward (lex prospicit non respicit).

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

GKN Driveshafts (India) Ltd. v. ITO
259 ITR 19 · 2003 · Supreme Court
1,349
citing judgments

When a notice under Section 148 of the Income Tax Act is issued, the Assessing Officer is bound to furnish reasons for reopening upon the assessee's request and must dispose of the assessee's objections to the notice by passing a speaking order.

Judgments citing Section 250(2)

M/S Care India Solutions for Sustainable Development, Delhi vs. DCIT, Central Circle-14, Delhi

ITA 7439/DEL/2025[2023-24]Status: DisposedITAT Delhi09 Mar 2026AY 2023-24

Bench: Sh. Raj Kumar Chauhan & Smt. Renu Jauhri

For Appellant: Sh. Pratik Arora, CAFor Respondent: Sh. Amit Jain, CIT-DR
Section 11Section 12ASection 147Section 148Section 148ASection 151Section 25Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH 'E', NEW DELHI Before Sh. Raj Kumar Chauhan, Judicial Member & Smt. Renu

M/S Care India Solution for Sustainable Development, Delhi vs. DCIT, Central Circle-14, Delhi

ITA 7438/DEL/2025[2022-23]Status: DisposedITAT Delhi09 Mar 2026AY 2022-23

Bench: Sh. Raj Kumar Chauhan & Smt. Renu Jauhri

For Appellant: Sh. Pratik Arora, CAFor Respondent: Sh. Amit Jain, CIT-DR
Section 11Section 12ASection 147Section 148Section 148ASection 151Section 25Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH 'E', NEW DELHI Before Sh. Raj Kumar Chauhan, Judicial Member & Smt. Renu

M/S Care India Solution for Sustainable Development, Delhi vs. DCIT, Central Circle-14, Delhi

ITA 7437/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Mar 2026AY 2016-17

Bench: Sh. Raj Kumar Chauhan & Smt. Renu Jauhri

For Appellant: Sh. Pratik Arora, CAFor Respondent: Sh. Amit Jain, CIT-DR
Section 11Section 12ASection 147Section 148Section 148ASection 151Section 25Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL DELHIBENCH `E', NEW DELHI Before Sh. Raj Kumar Chauhan, Judicial Member & Smt. Renu Jauhri

International Navodaya Chamber of Commerce, Delhi vs. CIT Exemption, Delhi

The appeals of the assessee are allowed for statistical purposes in above terms

ITA 7430/DEL/2025[2026-2027]Status: DisposedITAT Delhi09 Mar 2026AY 2026-2027

Bench: Sh. Raj Kumar Chauhan & Smt. Renu Jauhri

For Appellant: Sh. Sanjeev Goyal, CAFor Respondent: Sh. Amit Jain, CIT-DR
Section 12ASection 12A(1)(ac)Section 250(2)(a)Section 80G

mercy due to their conduct and appeal is required to be dismissed. 5. We have considered the rival submission and examined the record, Section 250(2)(a) of the Act lays down as under: “250(2) The following shall have the right to be heard at the hearing ... appeal- (a) the appellant, either in person or by an authorized representative;” 6. Thus, the hearing mandated by Section 250(2)(a) of the Act is not a mere formality but a mandatory statutory requirement for following the principle of natural justice by the quasi-judicial authority. We extract

International Navodaya Chamber of Commerce, Delhi vs. CIT Exemption Delhi, Delhi

The appeals of the assessee are allowed for statistical purposes in above terms

ITA 7429/DEL/2025[2026-2027]Status: DisposedITAT Delhi09 Mar 2026AY 2026-2027

Bench: Sh. Raj Kumar Chauhan & Smt. Renu Jauhri

For Appellant: Sh. Sanjeev Goyal, CAFor Respondent: Sh. Amit Jain, CIT-DR
Section 12ASection 12A(1)(ac)Section 250(2)(a)Section 80G

mercy due to their conduct and appeal is required to be dismissed. 5. We have considered the rival submission and examined the record, Section 250(2)(a) of the Act lays down as under: “250(2) The following shall have the right to be heard at the hearing ... appeal- (a) the appellant, either in person or by an authorized representative;” 6. Thus, the hearing mandated by Section 250(2)(a) of the Act is not a mere formality but a mandatory statutory requirement for following the principle of natural justice by the quasi-judicial authority. We extract

Haryana Bharat Vikas Foundation, Hisar vs. CIT Exemption, Chandigarh

ITA 7473/DEL/2025[-]Status: DisposedITAT Delhi09 Feb 2026

Bench: Shri S Rifaur Rahman & Shri Raj Kumar Chauhan

Section 12ASection 12A(1)(ac)Section 250(2)(a)Section 80G

mercy due to thereon conduct and appeal is required to be dismissed. 4. We have considered the rival submission and examined the record, Section 250(2)(a) lays down as under: - “250(2) The following shall have the right to be heard at the hearing of the appeal ... appellant, either in person or by an authorized representative;” 5. Thus, the hearing mandated by Section 250(2)(a) of the Act is not a mere formality but a mandatory statutory requirement for following the principle of natural justice by the quasi-judicial authority. We extract the para

Income Tax Officer, Ward - 2 (1), Varanasi vs. Prominent Datamatics Marketing Pvt. Ltd., Varanasi

ITA 135/VNS/2020[2017-2018]Status: DisposedITAT Varanasi05 Jan 2026AY 2017-2018

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 124(1)(a)Section 124(2)Section 124(3)(a)Section 250(1)Section 255(4)Section 69A

opportunity to examine/verify the claim of the assessee on merits of the additions. Reliance was placed by learned CIT Learned D. R. on section 250(2) of the 1961 Act and Rule 46A of the 1962 Rules. 6b. The Ld. Counsel for the assessee on the other hand submitted before

M/S Adrem India (P) Ltd., South Delh vs. Sh. Anshul, DCIT, Central Circle-20, Delhi

In the result, the appeal of the assessee is accordingly allowed in above terms for statistical purposes

ITA 5246/DEL/2024[2022-23]Status: DisposedITAT Delhi24 Dec 2025AY 2022-23

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwal

Section 132Section 250Section 28

have considered the rival submissions and examine the record. 9. Section 250 sub section 2(a) of "the Act" provides as under: “Section 250 (2) The following shall have the right to be heard at the hearing of the appeal: - a. The appellant, either in person or by an authorized ... that the Ld. CIT(A) has dismissed the appeal on merit ex parte without offering any effective opportunity of hearing as contemplated by Section 250(2) of the Act. We have noticed that there is nothing to show that the adjournment were taken on false grounds and seeking adjournment

Starkey Laboratories India Pvt. Ltd., Noida vs. DCIT Circle-24(2), New Delhi

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

ITA 3205/DEL/2023[2016-17]Status: DisposedITAT Delhi05 Dec 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalstarkey Laboratories Dy. Cit, India Pvt. Ltd., Circle-24(2), C-2, Sector-7, Vs. New Delhi. Gautam Buddha Nagar-201301, Uttar Pradesh. Pan-Aakcs6072R (Appellant) (Respondent)

Section 143(3)Section 250Section 250(1)(b)Section 37(1)Section 92C

provided to the assessee by ld. CIT(A) for virtual hearing, therefore, the Ld. CIT(A) has violated the mandatory provision of section 250(2) of the Act. The assessee also filed a written submission which read as under: GROUND 1: "On the facts and circumstances of the case ... passed an order without affording adequate opportunity of being heard as required u/s 250(1)(b) of Income Tax Act, 1961. Section 250(2) of the Act stipulates that CIT(A) shall dispose of the appeal only after giving the appellant an opportunity of being heard. The provision

Deputy Commissioner of Income Tax Circle 111, Surat vs. Mukesh Arjanbhai Maniya, Surat

In the result, appeal of revenue is dismissed

ITA 105/SRT/2025[2017-18]Status: DisposedITAT Surat03 Nov 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.105/Srt/2025 Assessment Year: 2017-18 (Hybrid Hearing) Deputy Commissioner Of Mukesh Arjanbhai Maniya बनाम/ Income Tax, Circle - 1(1)(1), C-303, Afil Tower, L.H. Road, Vs. Surat, Room No.108, 1St Varachha, Surat-395 006 Floor, Aayakar Bhawan, Majura Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Afepm 7227 A (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Sapnesh R Sheth, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 05/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 03/11/2025

Section 133ASection 139(1)Section 143(3)Section 148Section 250Section 250(2)Section 68

natural justice while admitting the additional evidences and not providing opportunity of being heard to the AO as per the provisions of section 250(2) of the Income tax Act, 1961 and Rule 46A(3) of the Income tax Rules, 1962 ? 5. On the facts and circumstances of the case ... afforded a chance to examine the evidence / rebut the assessee’s claim in violation of Rule 46A(3) and principles of natural justice [section 250(2)]. 8. On the other hand, Ld. AR of the assessee submitted a paper book consisting of copy of written submission filed before

Mangal Compusolution Limited, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -1(1) 2(3)(1), Mumbai

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

ITA 5172/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Oct 2025AY 2022-23

Bench: Shri Vikram Singh Yadav & Shri Raj Kumar Chauhan

For Appellant: Shri Akash Kumar (virtually present)For Respondent: Shri Surendra Mohan (SR. DR.)
Section 115BSection 143(1)Section 234ASection 250

effectively pursuing it and if a party retreats before the contest begins, it is as good as not having entered the fray.” Section 250(2)(a) reads as under:- 5 ITA 5172/Mum/2025 Mangal Compusolution Ltd “250 (1) The Appellate Assistant Commissioner shall fix a day and place for the hearing

Income Tax Officer, Ward-2(3)(1), Surat vs. Ambubhai Thakorbhai Patel, Surat

In the result, the appeal of the Revenue is dismissed and the CO of the assessee is allowed

ITA 1020/SRT/2024[2016-17]Status: DisposedITAT Surat17 Oct 2025AY 2016-17

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1020/Srt/2024 Assessment Year: 2016-17 (Hybrid Hearing) Income-Tax Officer Ward-2(3)(1), Ambubhai Thakorbhai Patel बनाम/ Surat, Room No. 614, 6Th Floor, 2/5 Bhesan, Gosai Faliyu Choryasi, Vs. Aaykar Bhawan, Majura Gate, Surat-395 005 Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ctopp 7620 J (अपीलाथ"/Appellant) (""थ" /Respondent) ""या"ेप सं /Co No.9/Srt/2025 (A/O Ita No.1020/Srt/2024/ (Ay 2018-19) Ambubhai Thakorbhai Patel Income-Tax Officer Ward-2(3)(1), बनाम/ 2/5 Bhesan, Gosai Faliyu Surat, Room No. 614, 6Th Floor, Vs. Choryasi, Surat-395 005 Aaykar Bhawan, Majura Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ctopp 7620 J (""यथ"/Respondent) (Co-Objector)

Section 147Section 148Section 250Section 250(2)Section 48

natural justice while admitting the additional evidences and not providing opportunity of being heard to the Assessing Officer as per the provisions of section 250(2) of the Income tax Act, 1961 and Rule 46A(3) of the Income tax Rules, 1962. iv. On the facts and circumstances

Income Tax Officer, Surat vs. Saffron Green International Private Limited, Surat

In the result, appeal of revenue is partly allowed

ITA 958/SRT/2024[2018-19]Status: DisposedITAT Surat26 Sept 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita No.958/Srt/2024 Assessment Year: 2018-19 (Hybrid Hearing) Income Tax Officer, Ward- Saffron Green International Pvt. बनाम/ 2(1)(3), Surat, Room No.221, Ltd. Shop No.3008, Shree Mahavir Vs. 2Nd Floor, Aaykar Bhavan, Textiles Puna Kumbhariya Road, Majura Gate, Surat-395 001 Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aawcs 3137 M (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Deven K. Kapadia, Ca राज" की ओर से /Respondent By Shri Aashish Pophare, Cit-Dr सुनवाई की तारीख/Date Of Hearing 10/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 26/09/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: This Appeal By The Revenue Emanates From The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, 'The Act’) Dated 16.07.2024 By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [In Short, ‘The Cit(A)’] For The Assessment Year (Ay) 2018-19, Which In Turn Arises Out Of Assessment Order Passed By The Assessing Officer (In Short, ‘Ao’) U/S. 147 R.W.S 144 R.W.S 144B Of The Act On 21.03.2023. 2. Grounds Of Appeal Raised By The Revenue Are As Under: “I. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Restricting The Addition Made By The Assessing Officer Of Rs.5,70,70,621/- On Account Of 100% Bogus Purchase To 0.25% Of The Bogus Purchases & Allowing The Appeal Of The Assessee Ignoring The Facts That These Purchases Are Sham Transactions Fabricated Through Bogus Paper Concerns Of M/S. Savitri Trading Company & Mohammed Javed Mohammed Jabir Momin Which Were Engaged In Providing Accommodation Entries.

Section 147Section 250Section 250(2)

natural justice while admitting the additional evidences and not providing opportunity of being heard to the AO as per the provisions of section 250(2) of the Income tax Act, 1961 and Rule 46A(3) of the Income tax Rules, 1962. vi. On the facts and circumstances of the case

DCIT, Circle-2(1)(1), Surat vs. Surendran Nanoo, Kerala

ITA 821/SRT/2024[2017-18]Status: DisposedITAT Surat26 Sept 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita No.821/Srt/2024 Assessment Year: 2017-18 (Hybrid Hearing)

Section 143(3)Section 250Section 250(2)Section 68

natural justice while admitting the additional evidences and not providing opportunity of being heard to the Assessing Officer as per the provisions of section 250(2) of the Income tax Act, 1961 and Rule 46A(3) of the Income tax Rules, 1962. 4. On the facts and circumstances ... against admission of additional evidence by CIT(A) without providing the opportunity of being heard to the AO as per the provisions of section 250(2) of the Act and Rule 46A(3) of the Income tax Rules, 1962. ITA No.821/Srt/2024 & CO 25/SRT/2024 A.Y 17-18 Surendran Nanoo

Pinkal Sureshkumar Kothari, Ahmedabad vs. The ITO, Ward-5(2)(1), Ahmedabad

In the result, the appeal filed by the assessee is allowed

ITA 1303/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad27 Aug 2025AY 2017-18

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 1303/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2017-18) बनाम/ Pinkal Sureshkumar Income Tax Officer Kothari Ward-5(2)(1), Vs. 4, Nemrajul Flat, Ahmedabad Navavikas Gruh Road, Vasna, Ahmedabad, Gujarat – 380007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Amlpk3944L (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Parth Mehta, A.R. ""यथ" क" ओर से/Respondent By : Shri Nitin Kulkarni, Sr. Dr

For Appellant: Shri Parth Mehta, A.RFor Respondent: Shri Nitin Kulkarni, Sr. DR
Section 143(2)Section 154Section 250Section 250(2)

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER आयकर अपील सं./I.T.A. No

Rakesh Kumar Jain, Jaipur vs. DCIT, Circle-2, Jaipur

In the result, the appeal filed by the assessee is allowed

ITA 212/JPR/2025[2014-15]Status: DisposedITAT Jaipur23 Jul 2025AY 2014-15

Bench: Or At The Time Of Hearing Of The Appeal & / Or Modify Any Of The Above Grounds.

For Appellant: Shri C.L. Yadav, CA and Shri Vikas Yadav AdvocateFor Respondent: Shri Gautam Singh Choudhary
Section 250(6)Section 271(1)(c)

opportunity to present his case, which is violation of the principles of natural justice. Reference in this regard may also be made to section 250(2)(a) of the Act, which guarantees the night to fair hearing, which was denied and therefore, the order passed

DCIT, Circle-1(3), Surat, Anavil Business Centre, Adajan vs. Shri Asfaq Hajiyunus Noorani, Rander

In the result, appeal of the revenue is dismissed

ITA 716/SRT/2023[2018-19]Status: DisposedITAT Surat30 Jun 2025AY 2018-19

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.716/Srt/2023 Assessment Year: (2018-19) (Hybrid Hearing) Dcit, Vs. Asfaq Hajiyunus Noorani, Circle – 1(3), 1, Abdullah Park, Gorat Road, Surat Rander, Surat - 395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaopn6148A (Appellant) (Respondent) Appellant By Shri Mukesh Jain, Cit-Dr Respondent By Shri Suresh K. Kabra, Ca Date Of Hearing 05/06/2025 Date Of Pronouncement 30/06/2025

Section 133(6)Section 250Section 250(2)Section 68

natural justice while admitting the additional evidences and not providing opportunity of being heard to the Assessing Officer as per the provisions of section 250(2) of the Income tax Act, 1961 and Rule 46A(3) of the income tax Rules, 1962. 2. On the facts and circumstances

Seema Srivastava, Patna vs. ITO, Dc/Ac-6, Patna

In the result, the appeal is dismissed

ITA 715/PAT/2024[2017-18]Status: DisposedITAT Patna06 Jun 2025AY 2017-18

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 144Section 250Section 250(2)Section 48Section 54Section 54F

आयकर अपीलीय अधिकरण पटना पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL PATNA BENCH AT KOLKATA [वर्चुअल कोटु] [Virtual

Income Tax Officer, Ward-1(3)(1), Surat, Adajan vs. Nita Ravi Khandelwal, Ghod Dod Road, Surat

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

ITA 813/SRT/2024[2016-17]Status: DisposedITAT Surat29 Apr 2025AY 2016-17

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.813/Srt/2024 Assessment Year: (2016-17) (Hybrid Hearing) The Ito, Vs. Nita Ravi Khandelwal, Ward – 1(3)(1), 33, Pratistha Awas, Ghod Dod Road, Surat Surat – 395007, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Agsps2820A (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Mukesh Jain, Sr. Dr Respondent By Shri Jaikishan Goel, Ca Date Of Hearing 13/02/2025 Date Of Pronouncement 29/04/2025

Section 250(2)Section 68

additional evidences and not providing opportunity of being heard to the Assessing Officer as per the ITA No.813/SRT/2023/AY.2016-17 Nita Ravi Khandelwal provisions of section 250(2) of the Income tax Act, 1961 and Rule 46A(3) of the income tax Rules, 1962. iv. On the facts and circumstances

Nafees Sultana, Hyederabad vs. Income Tax Officer, Ward-14(1), Hyderabad

ITA 642/HYD/2025[2014-15]Status: DisposedITAT Hyderabad28 Apr 2025AY 2014-15

Bench: Us:

For Appellant: Shri K. Sai Prasad. C.AFor Respondent: Dr.Sachin Kumar, Sr.DR
Section 147Section 148Section 194ISection 250Section 250(2)Section 25B

case and is, therefore, liable to be quashed. 2. Under the facts and circumstances of the case, the Honorable CIT(A) violated Section 250(2) of the Income Tax Act by passing the impugned order on 17th February 2025, the same day the appellant was directed to file submissions, thereby