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“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
43
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
34
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
34
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
32
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
21
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
14
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
13
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
11
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

Gati Kintetsu Express Private Limited, Maharashtra and Mumbai vs. Dy. Commissioner of Income Tax, Circle 14(1)(2), Mumbai, Maharashtra and Mumbai

In the result, In the result, appeal for AY 2013-14 is allowed partly for 14 is allowed partly for statistical purposes, purposes, appeal for AY 2014-15 is partly allowed, is partly allowed, appeal...

ITA 2831/MUM/2023[ASS YEAR 2015-2016]Status: DisposedITAT Mumbai13 May 2024

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Respondent: Mr. Madhur Agrawal
Section 143(3)Section 250

cireumstances of the case and in law, the Learned National Faceless Appeals Centre ("Ld. NFAC") vide order dated National Faceless Appeals Centre ("Ld. NFAC") vide order dated National Faceless Appeals Centre ("Ld. NFAC") vide order dated June 13, 2023 under section 250 of the Income ... facts and in circumstances of the case and in law, the Ld. NFAC erred in confirming the disallowance of made by t NFAC erred in confirming the disallowance of made by t NFAC erred in confirming the disallowance of made by the Ld. AO of depreciation amounting

Gati Kintetsu Express Private Limited, Mumbai vs. Dy Commissioner of Income Tax, Circle 14(1)(2), Mumbai

In the result, In the result, appeal for AY 2013-14 is allowed partly for 14 is allowed partly for statistical purposes, purposes, appeal for AY 2014-15 is partly allowed, is partly allowed, appeal...

ITA 2830/MUM/2023[ASST YEAR 2014-15]Status: DisposedITAT Mumbai13 May 2024

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Respondent: Mr. Madhur Agrawal
Section 143(3)Section 250

cireumstances of the case and in law, the Learned National Faceless Appeals Centre ("Ld. NFAC") vide order dated National Faceless Appeals Centre ("Ld. NFAC") vide order dated National Faceless Appeals Centre ("Ld. NFAC") vide order dated June 13, 2023 under section 250 of the Income ... facts and in circumstances of the case and in law, the Ld. NFAC erred in confirming the disallowance of made by t NFAC erred in confirming the disallowance of made by t NFAC erred in confirming the disallowance of made by the Ld. AO of depreciation amounting

Gati Kintetsu Express Pvt. Ltd, Maharashtra and Mumbai vs. Dy. Commissioner of Income Tax, Circle 14(1)(2), Mumbai, Maharashtra and Mumbai

ITA 2829/MUM/2023[ASS YEAR 2013-2014]Status: DisposedITAT Mumbai13 May 2024

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

For Respondent: Mr. Madhur Agrawal
Section 143(3)Section 250

reproduced as under: 1.1. On the facts and in circumstances of the case and in law, the Learned National Faceless Appeals Centre ("Ld. NFAC") vide order dated June 20, 2023 under section 250 of the Income tax Act, 1961 ("the Act") erred in confirming the order of the Learned Asst ... order dated March 31, 2015 be quashed and set 2.1 On the facts and in circumstances of the case and in law, the Ld. NFAC erred in confirming the disallowance made by the Ld. AO of depreciation amounting to Rs. 31,26,46,956 claimed on intangibles and goodwill arising

Kankaria Maninagar Nagrik Sahakari Bank Limited, Ahmedabad vs. The ADIT, CPC, Bangalore Present Juridiction the DCIT, Circle-2(1)(1), Ahmedabad

In the result, the appeal filed by the Assessee is allowed for statistical purpose

ITA 91/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad10 May 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(1)Section 154

Intimation. Therefore rejected the Rectification application filed by the assessee bank. 4. Aggrieved against the same, the assessee filed an appeal before Ld. NFAC which is also confirmed the addition. I.T.A No. 91/Ahd/2023 A.Y. 2018-19 3 Kankaria Maninagar Nagrik Sahakari Bank Ltd. vs. DCIT 5. Ld. Counsel Shri Rahul

Nitin Natwwarlal Patel, Vadodara vs. The Dy. Commissioner of Income Tax, Circle-1(2) Now Circle-1(1)(1), Vadodara

In the result, the appeal of the assessee is allowed

ITA 188/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad10 May 2024AY 2014-15

Bench: Smt.Annapurna Gupta & Ms. Suchitra Raghunath Kambleassessment Year : 2014-15 Nitin Natwarlal Patel Vs. Dcit, Cir.1(2), Now C-24, Mrc Colony Cir.1(1)(1) Gorwa, Vadodara. Vadodara. Pan : Agypp 3931 F (Applicant) (Responent) Assessee By : Shri Viranch Modi, Ar : Ms.Saumya Pandey Jain, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 14/02/2024 घोषणा क" तारीख /Date Of Pronouncement: 10/05/2024 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Viranch Modi, AR
Section 250

GUPTA, ACCOUNTANT MEMBER Present appeal has been filed by the assessee against order passed by the ld.Commissioner of Income (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 27.01.2023 under section 250 of the Income Tax Act, 1961 [hereinafter referred to as "the Act" for short] for the Asst.Year

Maruti Sadashiv Dhanavade, Kolhapur vs. The Income Tax Officer, Ward-1(4), Kolhapur

Appeal is partly allowed in above

ITA 538/PUN/2024[2017-18]Status: DisposedITAT Pune10 May 2024AY 2017-18

Bench: Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Kalpeshkumar Rupavatiya
Section 115BSection 143(3)Section 234ASection 68

Date of Pronouncement : 10.05.2024 ORDER This assessee’s appeal for assessment year 2017-18, arises against the National Faceless Appeal Centre [in short the “NFAC”] Delhi’s Din and Order No.ITBA/NFAC/S/250/ 2023-24/1059943819(1), dated 19.01.2024, in proceedings u/s.143(3) of the Income Tax Act, 1961 (in short

Krishan Kumar Tarachand, Pune vs. ITO (It) Ward -2, Pune

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

ITA 513/PUN/2024[2010-11]Status: DisposedITAT Pune10 May 2024AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.513/Pun/2024 िनधा"रण वष" / Assessment Year : 2010-11 Krishan Kumar Tarachand, Vs. Ito (It), Ward-2, Pune. Flat No.4, Anupam Apartments, Nda Pashan Road, Bavdhan Khurd, Pune- 411021 Pan : Abupd4503C Appellant Respondent Assessee By : None Revenue By : Shri Manoj Tripathi Date Of Hearing : 29.04.2024 Date Of Pronouncement : 10.05.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 09.07.2023 Passed By Ld Cit(A)/Nfac For The Assessment Year 2010-11. 2. The Appellant Raised The Following Grounds Of Appeal :- “1. (A) The Ld. National Faceless Appeal Centre (Nfac) Erred In Law & In Facts In Dismissing The Appeal Filed Against Penalty Order U/S. 271(1)(C) Of Income Tax Act, 1961 Dated 25.06.2018 Merely On The Premise That The Appeal Was Filed Belatedly & Without Providing Reasonable Opportunity Of Being Heard. (B) The Ld. Nfac Erred In Law In Dismissing The Appeal Filed Against Penalty Order U/S. 271(1)(C) Of Income Tax Act, 1961 Dated 25.06.2018 Levying A Penalty Of Rs.6,09,760/- Without

For Appellant: NoneFor Respondent: Shri Manoj Tripathi
Section 139Section 142(1)Section 144Section 148Section 271(1)(c)Section 275

/NFAC for the assessment year 2010-11. 2. The appellant raised the following grounds of appeal :- “1. (a) The Ld. National Faceless Appeal Centre (NFAC) erred in law and in facts in dismissing the appeal filed against penalty order u/s. 271(1)(c) of Income Tax Act, 1961 dated ... merely on the premise that the appeal was filed belatedly and without providing reasonable opportunity of being heard. (b) The Ld. NFAC erred in law in dismissing the appeal filed against penalty order u/s. 271(1)(c) of Income Tax Act, 1961 dated 25.06.2018 levying a penalty of Rs.6

Nagesh Shrimant Gavali, Pune vs. The Income Tax Officer, Ward 5(3), Pune

Appeal is allowed in above terms

ITA 5/PUN/2024[2012-13]Status: DisposedITAT Pune10 May 2024AY 2012-13

Bench: Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Shashank Deogadkar
Section 147Section 148

Date of Pronouncement : 10.05.2024 ORDER This assessee’s appeal for assessment year 2012-13, arises against the National Faceless Appeal Centre [in short the “NFAC”] Delhi’s Din and Order No. ITBA/NFAC/S/250/ 2023-24/1057676539(1), dated 03.11.2023, in proceedings u/s.147 of the Income Tax Act, 1961 (in short

Mohd Farooque Rafique Bagban, Nandurbar vs. Income Tax Officer, Ward-1, Dhule

Appeal is partly allowed in above terms

ITA 485/PUN/2024[2017-18]Status: DisposedITAT Pune10 May 2024AY 2017-18

Bench: Shri Satbeer Singh Godara

For Appellant: Smt. Deepa KhareFor Respondent: Shri Kalpesh Kumar Rupavatiya
Section 143(3)Section 68

SATBEER SINGH GODARA, J.M. : This assessee’s appeal for assessment year 2017-18, arises against the National Faceless Appeal Centre [in short the “NFAC”] Delhi’s Din and Order No. ITBA/NFAC/S/250/2023- 24/1054774826(1), dated 01.08.2023, in proceedings u/s.143(3) of the Income Tax Act, 1961 (in short “the Act”). Heard

Gyanoba Pandurang Panzade Trough His Legal Heir Manoj Gyanoba Panzade, Parbhani vs. ITO Officer, Parbhani

Appeal is allowed for statistical

ITA 447/PUN/2024[2011-12]Status: DisposedITAT Pune10 May 2024AY 2011-12

Bench: Shri Satbeer Singh Godara

For Appellant: CA Suhani MaharwalFor Respondent: Shri Somnath M Wajale
Section 147Section 2(11)Section 2(29)Section 249(4)(b)

Date of Pronouncement : 10.05.2024 ORDER This assessee’s appeal for assessment year 2011-12, arises against the National Faceless Appeal Centre [in short the “NFAC”] Delhi’s Din and Order No.ITBA/NFAC/S/250/ 2023-24/1060218034(1), dated 29.01.2024, in proceedings u/s.147 r.w.s.144 of the Income Tax Act, 1961 (in short ... Manoj Gyanoba Panzade claims himself to be the legal representative of the deceased assessee Gyanoba Pandurang Panzade on the one hand, whereas the learned NFAC has 2 ITA.No.447/PUN./2024 rejected the latter’s lower appeal for non-payment of advance tax u/sec.249(4)(b) of the Act. Meaning thereby

Rupmata Multistate Co-Operative Credit Society Ltd., Osmanabad vs. Income Tax Officer, Ward-1, Latur

The appeal is ALLOWED FOR STATISTICAL PURPOSE

ITA 400/PUN/2024[2020-21]Status: DisposedITAT Pune10 May 2024AY 2020-21

Bench: Hon’Ble Smt Astha Chandra & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 400/Pun/2024 निर्धारण वषा / Assessment Year : 2020-21 Rupmata Multistate Co-Operative Credit Society Ltd. 26/671, Rupmata Pride, Samarth Nagar, Dharashiv-413501 Pan: Aabar4836R . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Pratik Sandbhor [‘Ld. AR’]For Respondent: Mr Sourabh Nayak [‘Ld. DR’]
Section 143(3)Section 246A(1)(a)Section 250Section 56Section 80P

explained the reasons beyond postal delay of 4 days in instituting the present appeal and unsubstantial 62 days delay in instituting appeal before Ld. NFAC. In support of prayer for condonation & remand, it is submitted that, no part of the delay in instituting the present appeal and appeal before ... against the order of assessment dt. 28/03/2021 passed u/s 143(3) r.w.s. 144B of the Act, the assessee filed an appeal belatedly with Ld. NFAC on 26/12/2022 i.e. with a delay of 62 days. In absence of any supporting documents explaining the reasoning sufficiently to the satisfaction, the Ld. NFAC

Rupmata Zilla Nagari Sahakari Patsanstha Ltd., Osmanabad vs. Income Tax Officer, Ward-1, Latur

ITA 399/PUN/2024[2015-16]Status: DisposedITAT Pune10 May 2024AY 2015-16

Bench: Hon’Ble Smt Astha Chandra & Shri G. D. Padmahshaliआयकर अपऩल सं. / Ita No. 399/Pun/2024 निर्धारण वषा / Assessment Year : 2015-16 Rupmata Zilla Nagari Sahakari Pathsanstha Ltd. Samarth Nagar, Dharashiv-413501 Pan: Aaaar9677H . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Pratik Sandbhor [‘Ld. AR’]For Respondent: Mr Sourabh Nayak [‘Ld. DR’]
Section 142(1)Section 143(2)Section 144Section 246A(1)(a)Section 250Section 80PSection 80P(2)(a)

IN THE INCOME TAX APPELLATE TRIBUNAL, PUNE ‘B’ BENCH, PUNE BEFORE HON’BLE SMT ASTHA CHANDRA, JUDICIAL MEMBER AND SHRI

Raj Shankar Nikam, Pune vs. Income Tax Officer, Ward-2(2), Pune

Appeal is allowed in above terms

ITA 293/PUN/2024[2016-17]Status: DisposedITAT Pune10 May 2024AY 2016-17

Bench: Shri Satbeer Singh Godara

For Appellant: Shri Rohit S TapadiyaFor Respondent: Shri Manish Mehta
Section 147Section 148

Date of Pronouncement : 10.05.2024 ORDER This assessee’s appeal for assessment year 2016-17, arises against the National Faceless Appeal Centre [in short the “NFAC”] Delhi’s Din and Order No. ITBA/NFAC/S/250/ 2023-24/1058828465(1), dated 18.12.2023, in proceedings u/s.147 r.w.s.144 of the Income Tax Act, 1961 (in short ... factum of the assessee’s death is duly evident from perusal of page-13 in case file which was already submitted before the learned NFAC. That being the clinching case, the impugned proceedings initiated against a dead person have to be quashed indeed in light of Savita Kapila, Legal Heir

Shirish Digambarrao Deshpande (HUF), Parbhani vs. Income Tax Officer, Ward Hingoli, Parbhani

Appeal is partly allowed for

ITA 110/PUN/2024[2018-2019]Status: DisposedITAT Pune10 May 2024AY 2018-2019

Bench: Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Manish Mehta
Section 143(3)Section 271ASection 68

Date of Pronouncement : 10.05.2024 ORDER This assessee’s appeal for assessment year 2018-19, arises against the National Faceless Appeal Centre [in short the “NFAC”] Delhi’s Din and Order No.ITBA/NFAC/S/250/ 2023-24/1058230321(1), dated 24.11.2023, in proceedings u/s.143(3) of the Income Tax Act, 1961 (in short ... very terms coming to Rs.11,88,625/-. It is this impugned addition which stands 3 ITA.No.110/PUN./2024 upheld in the learned NFAC’s detailed discussion thereby rejecting the assessee’s arguments. 4. I have given my thoughtful consideration to assessee’s pleadings and Revenue’s vehement submissions reiterating their

Income Tax Officer, Nashik vs. Trambak Rubber Industries Private Limited, Sinnar, Nashik

Appeal is dismissed in above terms

ITA 845/PUN/2023[2010-11]Status: DisposedITAT Pune10 May 2024AY 2010-11

Bench: Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Manish Mehta
Section 143(3)Section 295

Date of Pronouncement : 10.05.2024 ORDER This assessee’s appeal for assessment year 2010-11, arises against the National Faceless Appeal Centre [in short the “NFAC”] Delhi’s Din and Order No. ITBA/NFAC/S/250/ 2023-24/1053340239(1), dated 31.05.2023, in proceedings u/s. 143(3) r.w.s.147 of the Income ... appellant craves leave to add, alter, amend and delete any ground (s) of appeal.” 3. Mr. Mehta invited my attention to the learned NFAC’s detailed discussion accepting the assessee’s arguments on merits reading as under : 3 ITA.No.845/PUN./2023 “7.8. At this juncture, it is important to look

M/S. Vadera Enterprises, Gondia vs. Income Tax Officer, Circle-5, Nagpur

Appeal is allowed in above terms

ITA 101/NAG/2023[2011-12]Status: DisposedITAT Nagpur10 May 2024AY 2011-12

Bench: Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Abhay Y. Marathe, Sr. DR
Section 143(3)Section 147Section 148

Date of Pronouncement : 10.05.2024 ORDER This assessee’s appeal for assessment year 2011-2012 arise against the National Faceless Appeal Centre [in short the “NFAC”] Delhi’s Din and Order No.ITBA/NFAC/S/250/2022- 23/1050156433(1) dated 27.02.2023, in proceedings u/s.143(3) of the Income Tax Act, 1961 (in short

M/S Apex Energy Resources Pvt. Ltd., Kolkata vs. ACIT, Cir. 7(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 33/KOL/2024[2013-14]Status: DisposedITAT Kolkata10 May 2024AY 2013-14

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 133(6)Section 143(3)Section 144BSection 147Section 148Section 148(2)Section 68

आदेश Per Rajesh Kumar, AM: This is the 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 08.11.2023 for the AY 2013-14. 2 I.T.A. No.33/Kol/2024 Assessment Year: 2013-14 M/s Apex ... Salarpuria Jajodia & Co., 7, C.R. Avenue, 3rd Floor, Kolkata-700072. 2. Respondent– ACIT, Circle-7(1), Kolkata (J.A.O) 3. Ld. CIT(A)-NFAC, Delhi 4. Pr. CIT- , Kolkata 5. DR, Kolkata Benches, Kolkata (sent through e-mail)By Order

Metal Box India Ltd., Kolkata vs. DCIT, Cir-11(1), Kol, Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 453/KOL/2023[2013-14]Status: DisposedITAT Kolkata10 May 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2013-14

For Appellant: Shri Manish Tiwari, ARFor Respondent: Shri P. P. Barman, Addl. CIT, Sr. DR
Section 14ASection 250

ACCOUNTANT MEMBER: This appeal filed by the assessee is against the order of the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “the Ld. CIT(A)”passed u/s. 250 of the Income Tax Act, 1961 (hereinafter referred ... Metal Box India Ltd., AY: 2013-14. Copy to: 1. The Appellant: 2. The Respondent. 3. CIT(A), NFAC, Delhi 4. The CIT, 5. DR, ITAT, Kolkata Bench, Kolkata //// By Order

M/S Ncs, Impex Holding Pvt. Ltd., Kolkata vs. ITO, Ward -8(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1394/KOL/2023[2012-13]Status: DisposedITAT Kolkata10 May 2024AY 2012-13

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarma]

Section 131Section 133(6)Section 143(1)Section 143(3)Section 144Section 68

Kumar, AM: This is an appeal preferred by the assessee against the order of ld. CIT(A), Income Tax Department, National Faceless Appeal Centre (NFAC), Delhi dated 29.11.2023 for A.Y. 2012-13. 2. The only issue raised by the assessee is against the order of ld. CIT(A) confirming

Sarthak Irrigation and Tractors, Barwani vs. ITO, Sendhwa

Appeal is allowed for statistical purpose

ITA 36/IND/2024[2017-18]Status: HeardITAT Indore10 May 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2017-18 M/S Sarthak Irrigation & Ito, Tractors, Sendhwa बनाम/ Near Aabhkari Office, Vs. Barwani (Assessee/Appellant) (Revenue/Respondent) Pan: Acbfs2994J Assessee By Shri S.N.Agrawal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 09.05.2024 Date Of Pronouncement 10.05.2024

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

Biyani, A.M.: Feeling aggrieved by appeal-order dated 30.12.2023 passed by learned Commissioner of Income-Tax (Appeals), NFAC, Delhi [“CIT(A)”] which in turn arises out of assessment-order dated 25.09.2019 passed by Income-tax Officer, Sendhwa [“AO”] u/s 144 of Income-tax Act, 1961 [“the Act”] for Assessment-Year