“NFAC”

Assessment ProceduresSection 144BSection 144B48,618 judgments

The decision most relied on for NFAC is Tecumseh Products India (P.) Ltd. v. DCIT (174 Taxmann.com 1203), cited in 43 judgments on BharatTax.

Leading authorities on NFAC

Tecumseh Products India (P.) Ltd. v. DCIT

174 Taxmann.com 1203 · 2025 · High Court

citing judgments

Where the National Faceless Assessment Centre (NFAC) and the Joint Assessing Officer (JAO) have concurrent jurisdiction, a notice issued by the JAO under Section 148 of the Income Tax Act is valid, provided no prejudice is caused to the assessee.

Aggarwal v. NFAC

127 Taxmann.com 637 · High Court

citing judgments

Denying a personal hearing when specifically requested, especially after a search and during a pandemic, violates the principles of natural justice. The assessment and appellate proceedings themselves were conducted during the COVID-19 pandemic.

Hire Purchase (P.) Ltd. v. NFAC

128 Taxmann.com 190 · High Court

citing judgments

Failure to grant a personal hearing to an assessee when income is likely to be varied based on submitted evidence violates the principles of natural justice and renders the assessment order invalid.

Prem Brothers Infrastructure LLP v. NFAC

142 Taxmann.com 38 · 2022 · High Court

citing judgments

When initiating penalty proceedings, the Assessing Officer (AO) must specify the limb of the charge, indicating whether the penalty is for concealment of income or furnishing inaccurate particulars. This requirement is essential for valid penalty proceedings.

Vinodkumar Lakshmipathi v. CIT (Appeals) NFAC

145 Taxmann.com 235 · 2022 · ITAT

citing judgments

The ITAT held that failure to file Form 67 by the due date for filing the return of income is not fatal to the claim for foreign tax credit. The appellate authority can condone the delay in filing Form 67.

Alrameez Construction (P.) Ltd. v. NFAC

152 Taxmann.com 382 · 2023 · ITAT

citing judgments

Penalty under Section 270A for under-reporting or mis-reporting of income cannot be sustained if additions are made under Section 56(2)(x) and the penalty notice fails to specify the limb under which proceedings are initiated.

Sanjay Gupta v. CIT

366 ITR 18 · 2014 · High Court

citing judgments

When the quantum of income is remanded to the Assessing Officer, the issue of penalty for undisclosed income should also be remanded to the Assessing Officer.

Saltwater Studio LLP v. NFAC

157 Taxmann.com 749 · 2023 · Reported

citing judgments

A penalty levied for misreporting under section 270A is unsustainable if the Assessing Officer fails to establish how the assessee's case falls within the specific instances of misreporting mentioned in section 270A(9). This requires an application of mind and adherence to the principles of natural justice.

Judgments citing NFAC

Prithvi Landcraft Private Limited, Noida vs. ACIT Circle 2(2)(1), Ghaziabad

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

ITA 1959/DEL/2023[2017-18]Status: DisposedITAT Delhi23 Jul 2024AY 2017-18

Bench: Shri Shamim Yahya & Shri Vimal Kumarprithvi Landcraft Private Limited, Vs. Acit, 4Th Floor, Avenue Apartment, Circle 2(2)(1), Village Barola, Sector 49, Ghaziabad. Noida – 201 301 (Uttar Pradesh). (Pan : Aagcp4666C) (Appellant) (Respondent) Assessee By : None Revenue By : Shri P.N. Barnwal, Cit Dr Date Of Hearing : 23.07.2024 Date Of Order : 23.07.2024 Order Per Shamim Yahyathis Appeal By The Assessee Is Directed Against The Order Of The Ld. Cit (Appeals)/National Faceless Appeal Centre (Nfac) Dated 19.12.2022 For The Assessment Year 2017-18. 2. Grounds Of Appeal Taken By The Assessee Read As Under :- “Dismissal Of The Grounds Of Appeal By The Hon’Ble Commissioner Of Income Tax (Appeals) Against The Order Passed U/S 144 Of The Income Tax Act, 1961 Of The Assessing Officer Due To Non- Compliance On The Part Of The Appellant Is Contrary To Facts & Law & Therefore, The Appeal Is Liable To Be Restored To The Assessing Officer Or To The Hon’Ble Commissioner Of Income Tax (Appeals) For Re-Assessment Or Decision On Merits Of The Issues On Which Additions Have Been Made.”

For Appellant: NoneFor Respondent: Shri P.N. Barnwal, CIT DR

Section 144Section 68

SHAMIM YAHYA, ACCOUNTANT MEMBER This appeal by the assessee is directed against the order of the ld. CIT (Appeals)/National Faceless Appeal Centre (NFAC) dated 19.12.2022 for the assessment year 2017-18. 2. Grounds of appeal taken by the assessee read as under :- “Dismissal of the grounds of appeal

Ramabhai Dhudabhai Patel, Deesa vs. The Income Tax Officer, Ward-1, Palanpur

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

ITA 1054/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad22 Jul 2024AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 1054/Ahd/2023 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2017-18) िनधा"रण वष" Ramabhai Dhudabhai Income Tax Officer बनाम बनाम/ बनाम बनाम Patel Ward – 1, Vs. Vardhman Complex, B/H. Palanpur Bhanshali Trust, College Road, Deesa, Banaskantha, Gujarat, 385535 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Apkpp2715C (Appellant) .. (Respondent) Shri Manthan Khokhani, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Shri Sanjay Jain, Sr. Dr Date Of Hearing 15/07/2024 Date Of Pronouncement 22/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi, (In Short ‘The Cit(A)’) Dated 17.10.2023 For The Assessment Year 2017-18. 2. The Brief Facts Of The Case Are That No Return Of Income For A.Y. 2013-14 Was Filed By The Assessee. It Transpired That The Assessee Had Deposited Cash Of Rs.19,29,021/- In Rbl Bank Ltd., Deesa Branch, Deesa During The Demonetization Period. The Case Was Selected For Scrutiny As Operation Clean Money (‘Omc’)

For Respondent: Shri Sanjay Jain, Sr. DR

Section 144Section 234Section 69A

SHRI NARENDRA PRASAD SINHA, AM: This appeal is filed by the assessee against the order of the National Faceless Appeal Centre (NFAC), Delhi, (in short ‘the CIT(A)’) dated 17.10.2023 for the Assessment Year 2017-18. 2. The brief facts of the case are that no return of income

Income Tax Officer, Ward-1(5), Aurangabad., Maharashtra vs. Royal Estates, Aurangabad, Maharashtra

In the result, the appeals of Revenue for AYs 2011-12 and 2012-13

ITA 34/PUN/2024[2011-12]Status: DisposedITAT Pune22 Jul 2024AY 2011-12

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

For Appellant: Shri Suhas P. BoraFor Respondent: Shri Sourabh Nayak

Section 143(3)Section 145(3)Section 147Section 69

alter or amend any/all of the grounds of appeal before or during the hearing of the appeal. 3. The Ld. CIT(A) NFAC erred in considering the fact that the information in the case of the assessee for the year under consideration was received from Valuation officer to whom ... Rs.2,57,21,478/-) and the same was added to the Income of the assessee u/s.69 of the Act. 4. Ld. CIT(A), NFAC erred in considering the fact that as the reference to the Valuation officer was not made during the year under consideration hence, the decision

Income Tax Officer Ward-1(5), Aurangabad, Maharashtra vs. Royal Estates, Aurangabad, Maharashtra

In the result, the appeals of Revenue for AYs 2011-12 and 2012-13

ITA 33/PUN/2024[2012-13]Status: DisposedITAT Pune22 Jul 2024AY 2012-13

Bench: Ms. Astha Chandra & Shree G.D. Padmahshali

For Appellant: Shri Suhas P. BoraFor Respondent: Shri Sourabh Nayak

Section 143(3)Section 145(3)Section 147Section 69

Akbar Virani, Hyderabad vs. ITO., Ward-4(1), Hyderabad

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

ITA 468/HYD/2024[2017-18]Status: DisposedITAT Hyderabad22 Jul 2024AY 2017-18

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia, Hon’Bleassessment Year: 2017-18 Akbar Virani, Vs. The Income Tax Oficer, Ward – 4(1), Hyderabad. Hyderabad. Pan : Aegpv9662P. (Appellant) (Respondent) Assessee By: Shri Vemulapati Sridhar, C.A. Revenue By: Shri Shakeer Ahamed, Sr.Ar Date Of Hearing: 11.07.2024 Date Of Pronouncement: 22.07.2024

For Appellant: Shri Vemulapati Sridhar, C.AFor Respondent: Shri Shakeer Ahamed, Sr.AR

Section 142(1)Section 147Section 148Section 272A(1)(d)Section 69

This appeal is filed by the assessee, feeling aggrieved by the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 05.03.2024 for the AY 2017-18. 2 2. The assessee has raised the following grounds : ““1. The appellant submits that the order ... Feeling aggrieved by the order passed by the assessing officer, assessee filed appeal before the Ld. CIT(A) / NFAC, who dismissed the appeal of assessee. 5. Feeling aggrieved with the order of ld.CIT(A), assessee is now in appeal before us. 4 6. Firstly, the ld. AR has drawn

Income Tax Officer, Ward-6(1), Hyderabad vs. Venkata Krishnamohan Nakka, Hyderabad

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

ITA 343/HYD/2024[2013-14]Status: DisposedITAT Hyderabad22 Jul 2024AY 2013-14

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M. Machar Rao, AdvocateFor Respondent: : Shri Shakeer Ahamed, DR

Section 142Section 147Section 148

appeal is filed by the Revenue, feeling aggrieved by the order passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”), dated 07.02.2024 for the A.Y. 2013-14. 02. The Revenue has raised the following grounds : “ 1. The CIT(A) erred

Madhuri Chinthamaneni, Hyderabad vs. Asst. Commissioner of Income Tax, Circle 12(1), Hyderabad

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

ITA 338/HYD/2024[2019-20]Status: DisposedITAT Hyderabad22 Jul 2024AY 2019-20

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri S.K. Gupta, AdvocateFor Respondent: : Shri Shakeer Ahamed, DR

Section 10Section 144Section 80DSection 80T

filed by Madhuri Chinthamaneni (“the assessee”), feeling aggrieved by the order passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”), dated 05.02.2024 for the A.Y. 2019-20. 02. The assessee has raised the following grounds : 1. The order

Sree Kanyaka Mutually Aided Co-Op Thrift Credit and Marketg. Society Limited, Hindupur vs. Income Tax Officer, Ward 1, Hindupur

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

ITA 224/HYD/2024[2018-19]Status: DisposedITAT Hyderabad22 Jul 2024AY 2018-19

Bench: Shri Laliet Kumar, Hon’Ble & Shri Madhusudan Sawdia

For Appellant: Shri D. Shree Raksha, CAFor Respondent: Shri Shakeer Ahamed, DR

Section 143(3)Section 56Section 80PSection 80P(2)(a)

Society Limited, Hindupur (“the assessee”), feeling aggrieved by the separate orders passed by the learned Commissioner of Income Tax (Appeals)- National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”), dated 06.02.2024 and 04.01.2024 for the A.Ys. 2018-19 and 2020-21, respectively. 2. Since, the facts are identical and issues

Shailendra Kumar Gupta, Kolkata vs. D.C.I.T., Circle - 32(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 990/KOL/2024[2017-2018]Status: DisposedITAT Kolkata22 Jul 2024AY 2017-2018

Bench: me. I observe that the assessee is an Shailendra Kumar Gupta

Section 69A

present appeal is directed at the instance of assessee against the order of ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 9th March, 2024 passed for assessment year 2017-18. 1 Shailendra Kumar Gupta 2. The grounds of appeal raised by the assessee read ... Deputy Commissioner of Income Tax, Circle-32(1), Kolkata, 10B, Middleton Row, Kolkata-700071; (3) Commissioner of Income Tax (Appeals), National Faceless Appeal Centre(NFAC), Delhi; (4) CIT- , Kolkata; 4 Shailendra Kumar Gupta (5) The Departmental Representative; (6) Guard FileBy order

M/S. Blueprint Commercial Pvt. Ltd., Kolkata vs. I.T.O., Ward - 5(1), Kolkata

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

ITA 945/KOL/2024[2013-2014]Status: DisposedITAT Kolkata22 Jul 2024AY 2013-2014

Bench: Dr. Manish Boradi.T.A. No.945/Kol/2024 Assessment Year: 2013-14

Section 147Section 250Section 68

passed u/s 250 of the Income Tax Act, 1961 in short the “Act”) by Ld. Commissioner of Income-tax (Appeal), National Faceless Appeal Centre (NFAC), Delhi [in short Ld. “CIT(A)”] dated 13.07.2023 arising out of the assessment order u/s 147 r.w.s. 144 of the Act by ITO, Ward ... Blueprint Commercial Pvt. Ltd., 284/B, Bipin Bihari Ganguly Street, Ground Floor, Kolkata-700012. 2. Respondent – ITO, Ward-5(1), Kolkata 3. CIT(A), NFAC, Delhi 4. CIT- 5. Departmental Representative 6. Guard File.By order

Hirak Sarkar, Hooghly vs. ACIT, Circle 23(1), Hooghly

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

ITA 925/KOL/2024[2013-2014]Status: DisposedITAT Kolkata22 Jul 2024AY 2013-2014

Bench: Dr. Manish Boradi.T.A. No.925/Kol/2024 Assessment Year: 2013-14

Section 147Section 250

passed u/s 250 of the Income Tax Act, 1961 in short the “Act”) by Ld. Commissioner of Income-tax (Appeal), National Faceless Appeal Centre (NFAC), Delhi [in short Ld. “CIT(A)”] dated 21.03.2024 arising out of the assessment order u/s 147 r.w.s. 143(3) of the Act by ACIT, Circle ... Appellant – Shri Hirak Sarkar, 37/C, Bose Para Lane, Serampore, West Bengal-712202. 2. Respondent – ACIT, Circle-23(1), Hooghly 3. CIT(A), NFAC, Delhi 4. CIT- 5. Departmental Representative 6. Guard File.By order

Shri Kalyan Das Gupta, Kolkata vs. ITO, Ward 45(3), Kolkata

ITA 9/KOL/2024[2015-16]Status: DisposedITAT Kolkata22 Jul 2024AY 2015-16

Bench: Sri Rajesh Kumar & Sri Anikesh Banerjee

order forwarded to: 1. Shri Kalyan Das Gupta, 127, Santoshpur Avenue, Santoshpur-700 075 2. ITO, Ward-5(3), Kolkata. 3. CIT(A)-NFAC, Delhi. 4. CIT- 5. CIT(DR), Kolkata Benches, Kolkata. //// By order

Mrs. Neelam Agrawal, Kolkata vs. ITO, Ward-37(1), Kolkata

In the result, appeal of the assessee is allowed

ITA 756/KOL/2024[2015-16]Status: DisposedITAT Kolkata22 Jul 2024AY 2015-16

Bench: Dr. Manish Borad & Shri Pradip Kumar Choubeyi.T.A. No.756/Kol/2024 Assessment Year: 2015-16 Mrs. Neelam Agarwal ………. Appellant (Pan: Adcpa3772G) Vs. Income Tax Officer, Ward-37(1), Kolkata. ………… Respondent Appearances By: Shri Sunil Surana, Ar Appeared For Appellant. Shri Abhijit Kundu, , Addl. Cit, Dr Appeared For Respondent. Date Of Concluding The Hearing : 03.07.2024 Date Of Pronouncing The Order : 22.07.2024 Order Per Manish Borad: This Appeal Filed By The Assessee Pertaining To The Assessment Year (In Short “Ay”) 2015-16 Is Directed Against The Revision Order Passed U/S 263 Of The Income Tax Act, 1961 In Short The “Act”) By Ld. Pr. Commissioner Of Income-Tax, Kolkat-13 [In Short Ld. “Pr. Cit”] Dated 15.03.2024 Arising Out Of The Assessment Order U/S 147 R.W.S. 144B Of The Act By Ao, Nfac, Delhi Dated 27.03.2022. 2. Grounds Of Appeal Raised By The Assessee Read As Under: “1. For That The Ld. Pcit Erred In Revising The Reassessment Order Which Was Itself Invalid & Bad In Law As Sanction For Reopening Of Assessment Proceedings Was Not Taken From Prescribed Authority As Per Section 151. I.T.A. No. 756/Kol/2024 Neelam Agarwal, Ay : 2015-16

Section 144BSection 147Section 148Section 151Section 263

Kolkat-13 [in short Ld. “Pr. CIT”] dated 15.03.2024 arising out of the assessment order u/s 147 r.w.s. 144B of the Act by AO, NFAC, Delhi dated 27.03.2022. 2. Grounds of appeal raised by the assessee read as under: “1. For that the Ld. PCIT erred in revising the reassessment

Onkara Infratech Pvt. Ltd., Kolkatqa vs. ITO, Ward-6(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 558/KOL/2024[2013-14]Status: DisposedITAT Kolkata22 Jul 2024AY 2013-14

Bench: the ld. CIT(Appeals) and succeeded, but before passing of the order by ld. CIT(Appeals), ld. PCIT carried out the revisionary proceedings and directed the ld. Assessing Officer to reframe the assessment by not estimating the addition of 21% but to make the total addition of the alleged difference. In compliance, the ld. Assessing Officer passed the order on 31.07.2018 and made the total addition. Being aggrieved, the assessee preferred appeal before the ld. CIT(Appeals), but due to unavoida

Section 143(3)Section 250Section 263

present appeal is directed at the instance of assessee against the order of ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 14th November, 2023 passed for assessment year 2013-14. 1 Onkara Infratech Pvt. Ltd. 2. The grounds of appeal raised by the assessee ... Kolkata, Aayakar Bhawan, P-7, Chowringhee square, Kolkata-700069 7 Onkara Infratech Pvt. Ltd. (3) Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi; (4) CIT- , Kolkata (5) The Departmental Representative; (6) Guard FileBy order

Shree Balajee Agro Mills Pvt. Ltd., Kolkata vs. ITO, Ward-5(1), Kolkata

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

ITA 45/KOL/2024[2013-14]Status: DisposedITAT Kolkata22 Jul 2024AY 2013-14

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 143(3)Section 144Section 147Section 148

आदेश Per Rajesh Kumar, AM: This is an appeal preferred by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi dated 07.11.2023 for the AY 2013-14. 2. Issue raised in first grounds of appeal is against the order of Ld. CIT(A) passing

Nisha Bhattacharyya, Kolkata vs. CIT(A), Kolkata

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

ITA 121/KOL/2024[2019-20]Status: DisposedITAT Kolkata22 Jul 2024AY 2019-20

Bench: Dr. Manish Borad (Accountant Member)

Section 143(1)(a)Section 143(3)Section 37(1)

present appeal is directed at the instance of assessee against the order of ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 21st November, 2023 passed for assessment year 2019-20. 2. The grounds of appeal raised by the assessee read as under:- 1 Nisha Bhattacharyya ... Bhattacharyya (2) Commissioner of Income Tax (Appeals), Ward No. 22(1), Kolkata, West Bengal; (3) Commissioner of Income Tax (Appeals), National Faceless Appeal Centre(NFAC), Delhi; (4) CIT- , Kolkata; (5) The Departmental Representative; (6) Guard FileBy order

Gulab Grandsons Foundation, Kolkata vs. ITO, Kolkata

In the result, the appeal of the assessee is allowed

ITA 353/KOL/2023[2018-19]Status: DisposedITAT Kolkata22 Jul 2024AY 2018-19

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 139Section 139(9)Section 164(1)Section 164(3)Section 44A

आदेश Per Rajesh Kumar, AM: This is an appeal preferred by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi (hereinafter referred to as the Ld. CIT(A)”] dated 31.03.2023 for the AY 2018-19. 2. The issue raised in the appeal ... Foundation, Unit No. 1501, 15th Floor, Diamond Heritage, 16,Strand Road, Kolkata-700001 2. Respondent – ITO, Ward-1(1), Kolkata 3. Ld. CIT(A)- NFAC, Delhi 4. DR, Kolkata Benches, Kolkata (sent through e-mail)By Order

M/S Country Spirit Shop, Howrah vs. ITO, Ward 46(3), Kolkata

In the result, both the appeals of the assessee are allowed

ITA 1307/KOL/2023[2015-16]Status: DisposedITAT Kolkata22 Jul 2024AY 2015-16

Bench: Dr. Manish Borad (Accountant Member)

above appeals are directed at the instance of assessee against the orders of ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, both dated 27th September, 2023 passed for assessment years 2014-2015 & 2015- 16 respectively arising out of the assessment order dated 25.11.2016 and 04.12.2017 respectively ... Income Tax Officer, Ward-46(3), Kolkata, 3, Government Place (West), Kolkata-700001 (3) Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi; (4) CIT- , Kolkata (5) The Departmental Representative; (6) Guard FileBy order

M/S Country Spirit Shop, Howrah vs. ITO, Ward 46(3), Kolkata

In the result, both the appeals of the assessee are allowed

ITA 1306/KOL/2023[2014-15]Status: DisposedITAT Kolkata22 Jul 2024AY 2014-15

Bench: Dr. Manish Borad (Accountant Member)

The Erode City Municipal Corporation Emp Co-Op T& C Limited, Chennai vs. ITO, Ward 1 (1), Erode

In the result, the appeal in ITA No

ITA 510/CHNY/2024[2020-21]Status: DisposedITAT Chennai22 Jul 2024AY 2020-21

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.509 & 510/Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-2019 & 2020-2021)

For Appellant: Ms. G. Vardini Karthik, AdvocateFor Respondent: Shri ARV Srinivasan, IRS, Addl. CIT

Section 119(2)(b)Section 139(1)Section 139(4)Section 143(1)Section 143(2)Section 2(6)Section 80ASection 80PSection 80P(2)(a)

Judicial Member) These two Income Tax Appeals filed by the assessee are directed against the order of the Ld. Commissioner of Income Tax(Appeal)(NFAC) Delhi [CIT(A)] dated 09.01.2024 and dated 08.01.2023 for Assessment Years 2018-19 and 2020-21 respectively. Adjudication on Appeal