“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

Modland Wears P.Ltd, New Delhi vs. DCIT, Circle 16(1), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1658/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Feb 2024AY 2018-19

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Gaurav Jain, AdvFor Respondent: Shri Subhra Jyoti Chakraborty, CIT-DR

Section 36(1)(iii)

Date of Pronouncement : 07.02.2024 ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER:- This appeal by the assessee is preferred against the order dated 31.03.2023 by NFAC, Delhi pertaining to A.Y. 2018-19. 2. The sum and substance of the grievance of the assessee is that the CIT(A) erred in confirming

Vishram Sahakari Awas Samiti Limited, G.Noida vs. ITO, Ward-2(5), Noida

In the result, appeal of the assessee stands allowed

ITA 1667/DEL/2021[2011-12]Status: DisposedITAT Delhi07 Feb 2024AY 2011-12

Bench: Shri Shamim Yahya & Shri Anubhav Sharma

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Amit Katoch, Sr. DR

Section 147Section 148Section 68

ORDER PER SHAMIM YAHYA, A.M. This appeal by the Assessee is directed against the order passed by the Learned Commissioner of Income Tax (Appeals)/ NFAC, New Delhi, dated 15/09/2021 and pertains to Assessment Year 2011-12. The grounds of appeal are as under: “1. On the facts and circumstances

Haribhai Patel, Gandhinagar vs. The Income Tax Officer, Ward-2, Gandhinagar

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

ITA 791/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad06 Feb 2024AY 2017-18

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Respondent: Shri B. P. Makwana, Sr. DR

Section 144

instant appeal filed at the instance of the assessee is directed against the order dated 16.08.2023 passed by the National Faceless Appeal Centre (NFAC), Delhi, arising out of the order dated 21.11.2019 passed by the ITO, Ward-2, Gandhinagar, under Section 144 of the Act for Assessment Year

Vikrambhai Ambalal Patel HUF, Dharmaj vs. The DCIT Circle 1(3) Vadodara (Now, the DCIT Circle 1(1)(1) Baroda), Baroda

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

ITA 645/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad06 Feb 2024AY 2013-14

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Respondent: Shri Ashok Kumar Suthar, Sr. DR

Section 143(3)

instant appeal filed at the instance of the assessee is directed against the order dated 28.06.2023 passed by the National Faceless Appeal Centre (NFAC), Delhi, arising out of the order ITA No. 645/Ahd/2023 (Vikrambhai Ambalal Patel HUF vs. DCIT) A.Y.– 2013-14 - 2 – dated 30.03.2016 passed by the Assessing Officer ... before the concerned CIT(A) and the same was never decided against the appellant of being filed late. Once the appeal was transferred to NFAC as per Scheme, the appeal was dismissed on the ground of barred by limitation wrongly as also the contention made by the Ld. AR before

M/S. Vrajesh Agencies, Vadodara vs. The Income Tax Officer, Ward-1(2)(5), Vadodara

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

ITA 190/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad06 Feb 2024AY 2013-14

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 190/Ahd/2023 ("नधा"रण वष" / Assessment Year : 2013-14) M/S. Vrajesh Agencies Income Tax Officer, बनाम/ A-9/5, Urmi Apartments, Ward 1(2)(5), Vadodara Vs. Fatehgunj, Vadodara "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabfv1170B (Appellant) .. (Respondent) Shri Hemant Suthar, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Shri Sushil Kumar Katiar, Sr. Dr 01/02/2024 Date Of Hearing 06/02/2024 Date Of Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Instant Appeal Filed At The Instance Of The Assessee Is Directed Against The Order Dated 13.02.2023 Passed By The National Faceless Appeal Centre (Nfac), Delhi, Arising Out Of The Order Dated 18.03.2016 Passed By The Ito, Ward-1(2)(5), Vadodara, Under Section 143(3) Of The Act For Assessment Year 2013-14. 2. The Appeal Was Dismissed Ex Parte By Nfac, Delhi As None Appeared On Behalf Of The Appellant In Spite Of Several Notices Issued To The Appellant. However, Since Order Passed By The Ld.

For Respondent: Shri Sushil Kumar Katiar, Sr. DR

Section 143(3)Section 250(6)

instant appeal filed at the instance of the assessee is directed against the order dated 13.02.2023 passed by the National Faceless Appeal Centre (NFAC), Delhi, arising out of the order dated 18.03.2016 passed by the ITO, Ward-1(2)(5), Vadodara, under Section 143(3) of the Act for Assessment ... Year 2013-14. 2. The appeal was dismissed ex parte by NFAC, Delhi as none appeared on behalf of the appellant in spite of several notices issued to the appellant. However, since order passed by the Ld. ITA No. 190/Ahd/2023 (M/s. Vrajesh Agencies

Vineet Bahety, Kolkata vs. ITO, Ward-44(2), Kolkata

In the result, both the appeals filed by the assessee are allowed

ITA 1267/KOL/2023[2020-21]Status: DisposedITAT Kolkata06 Feb 2024AY 2020-21

Bench: Sri Rajpal Yadav & Dr. Manish Borad

Section 143(1)Section 250Section 90

Assessment Year: 2019-20 “1.1 That on the facts and in the circumstances of the case, the Learned CIT(Appeals)/Addl./Joint CIT(Appeals), NFAC [here in after referred to as Ld. CIT(Appeals), NFAC] was not justified and grossly erred in confirming the disallowance of Foreign Tax Credit ... read with Article 23 of India- Indonesia DTAA. 1.2 That on the facts and in the circumstances of the case, the Ld. CIT(Appeals), NFAC was not justified and grossly erred in confirming the late filing of Form No. 67 invalid for availing treaty (DTAA) benefit. 1.3 That

Vineet Bahety, Kolkata vs. ITO, Ward-44(2), Kolkata.

In the result, both the appeals filed by the assessee are allowed

ITA 1266/KOL/2023[2019-20]Status: DisposedITAT Kolkata06 Feb 2024AY 2019-20

Bench: Sri Rajpal Yadav & Dr. Manish Borad

Section 143(1)Section 250Section 90

Bisharpara Kodalia Cooperative Credit Society Ltd., Dumdum vs. ITO, Ward-49(2), Kolkata.

In the result, appeal of the assessee is allowed

ITA 1248/KOL/2023[2018-19]Status: DisposedITAT Kolkata06 Feb 2024AY 2018-19

Bench: Shri Rajpal Yadav & Shri Girish Agrawalassessment Year: 2018-19 Bisharpara Kodalia Cooperative Income Tax Officer, Ward- Credit Society Ltd. 49(2), Kolkata Vs. Nabajiban, Bisharpara, Dum Dum, West Bengal-700158. (Pan: Aaaab9104B) (Appellant) (Respondent)

For Appellant: Shri Indranil Banerjee, FCAFor Respondent: Shri B. K. singh, JCIT, Sr. DR

Section 10ASection 139Section 139(4)Section 143Section 143(1)Section 143(1)(a)Section 154Section 80PSection 80P(2)(b)Section 80P(2)(d)

GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the order of Ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi vide order No. ITBA/NFAC/S/250/2023-24/1056371269(1) dated 21.09.2023 passed against the Intimation u/s.143(1) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”), dated ... under: “1. That on the facts and circumstances of the case and in law, the Appellate Order, passed by the Ld. CIT(A)-NFAC, whereby the Appeal has been dismissed on the alleged ground of non-compliance, for being contrary to facts on record and law, would call for total

Seema Jaiswal, Bhopal vs. CIT(A), Delhi

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

ITA 415/IND/2023[2011-12]Status: DisposedITAT Indore06 Feb 2024AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniseema Jaiswal Dcit 3(1) Flat-68, Meenal Residency, Bhopal J.K. Road Vs. Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Adhpj0961D Assessee By Assesse In Person Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 06.02.2024 Date Of Pronouncement 06.02.2024

Section 142(1)Section 144Section 147Section 148

Vijay Pal Rao, JM : This appeal by the Assessee is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC) dated 04.09.2023 for A.Y. 2011-12. The assessee has raised following grounds of appeal: “1 . That the reasons recorded u/s 147 and the consequent notice

Samveg Bhandari, Indore vs. Income Tax Officer, Delhi

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

ITA 291/IND/2023[2021-22]Status: DisposedITAT Indore06 Feb 2024AY 2021-22

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisamveg Bhandari Ito- Nfac Bunglow No.1, Shalimar Delhi Township Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Ajfpb 6700N Assessee By Shri Subhash Chand Jain, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 05.02.2024 Date Of Pronouncement 06.02.2024

Section 143(1)Section 154

INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER AND SHRI B.M. BIYANI, ACCOUNTANT MEMBER Samveg Bhandari ITO- NFAC Bunglow No.1, Shalimar Delhi Township Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) PAN: AJFPB 6700N Assessee by Shri Subhash Chand Jain, AR Revenue by Shri Ashish Porwal ... Vijay Pal Rao, JM : This appeal by the Assessee is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC) dated 05.06.2023 arising from order passed by the CPC u/s 154 r.w. section 143(1) of the Act for A.Y. 2021-22. The assessee

Radhey Shyam Yadav, Jaipur vs. Income Tax Officer, Jaipur

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

ITA 814/JPR/2023[2011-2012]Status: DisposedITAT Jaipur06 Feb 2024AY 2011-2012

For Appellant: Ms. Nargis Parveen, CAFor Respondent: Mrs. Monisha Choudhary, Addl CIT-DR

Section 139(1)Section 144Section 148Section 69

assessee is directed against order of the ld. CIT(A) dated 10-12-2023, National Faceless Appeal Centre, Delhi [hereinafter referred to as (NFAC)] for the assessment year 2011-12 wherein the assessee has raised the following grounds of appeal. "1. That the learned AO has erred

Star Valley Heights LLP, Jaipur vs. Income Tax Officer Ward 3(2), Jaipur

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

ITA 806/JPR/2023[2017-2018]Status: DisposedITAT Jaipur06 Feb 2024AY 2017-2018

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Saurav Harsh, AdvFor Respondent: Mrs. Monisha Choudhary, Addl CIT-DR

Section 115BSection 250

assessee is directed against order of the ld. CIT(A) dated 16-10-2023, National Faceless Appeal Centre, Delhi [ hereinafter referred to as (NFAC) ] for the assessment year 2017-18 wherein the assessee has raised the following grounds of appeal. ‘’1. That on the facts and circumstances of the case ... appellant neither made any written submissions nor filed any application seeking adjournment. After enabling the window for communication with the CIT(A), by the NFAC with effect from 07/11/2022 also, no communication has been received from the appellant till date. Considering the above facts, it is clear that, in this

R.K. Sansthan, Jaipur vs. CIT (Exemption), Jaipur

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

ITA 777/JPR/2023[2024-25]Status: DisposedITAT Jaipur06 Feb 2024AY 2024-25

For Appellant: Shri Neeraj Lalwani, ProxyFor Respondent: Ms. Chanchal Meena, Addl. CIT-DR

Section 147Section 269SSection 271DSection 272A(1)

assessee is directed against order of the ld. CIT(A) dated 30-12-2022, National Faceless Appeal Centre, Delhi [hereinafter referred to as (NFAC)] for the assessment year 2010-11 wherein the assessee has raised the following grounds of appeal. "1. Order passed by the AO u/s 271D r.w.s

Usha Infra, Ajmer vs. ITO Ward-1, Beawer

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

ITA 703/JPR/2023[2018-19]Status: DisposedITAT Jaipur06 Feb 2024AY 2018-19

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Vedant Agarwal, AdvFor Respondent: Shri A.S. Nehra, Addl CIT-DR

Section 144Section 68

assessee is directed against order of the ld. CIT(A) dated 29-09-2023, National Faceless Appeal Centre, Delhi [ hereinafter referred to as (NFAC) ] for the assessment year 2018-19 wherein the assessee has raised the following grounds of appeal. ‘’1. On the facts and circumstances of the case

Marulasidappa Gundagathi Dyamavvanahalli, Davangere vs. Income-Tax Officer, Ward-1, Davangere

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

ITA 898/BANG/2023[2010-11]Status: DisposedITAT Bangalore06 Feb 2024AY 2010-11

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2010-11 Marulasidappa Gundagathi Dyamavvanahalli #2035/148, Nutan Nilaya Ito 12Th Cross, Anjaneya Badavane Ward-1 Vs. Davanagere 577 005 Davangere Karnataka Pan No.Agepd9313P Assessee Respondent Assessee By : Shri V. Srinivasan, A.R. Revenue By : Shri Aparithivel, D.R. Date Of Hearing : 06.02.2024 Date Of Pronouncement : 06.02.2024 O R D E R Per Chandra Poojari: This Appeal By Assessee Is Directed Against Order Of Nfac For The Assessment Year 2010-11 Dated 29.9.2023 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). The Assessee Has Raised Following Grounds Of Appeal: 1: The Orders Of The Authorities Below In So Far As They Are Against The Appellant Are Opposed To Law, Equity, Weight Of Evidence, Probabilities, Facts & Circumstances Of The Case.

For Appellant: Shri V. Srinivasan, A.RFor Respondent: Shri AParithivel, D.R

Section 142Section 234Section 250Section 68

Date of Pronouncement : 06.02.2024 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by assessee is directed against order of NFAC for the assessment year 2010-11 dated 29.9.2023 passed u/s 250 of the Income Tax Act, 1961 (in short “The Act”). The assessee has raised following ... proved :Rs.4,76,430/- Total Income assessed R/o :Rs.3,47,32,950/-“ 2.2 Against this assessee carried the appeal before CIT(A)/NFAC. Before NFAC, no reply has been filed. Accordingly, the NFAC observed that ld. AO has passed speaking order with detailed discussion on the issue involved therein

Vittal Grameena Sahakari Bank Niyamitha, Vittal vs. Income-Tax Officer, Ward-2(5), Mangaluru

ITA 895/BANG/2023[2017-18]Status: DisposedITAT Bangalore06 Feb 2024AY 2017-18

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2017-18 Vittal Grameena Sahakari Bank Niyamitha F.F. 94, Palace Road Vittal Bantwal Taluk Ito Vs. Vittal 574 222 Ward-2(5) Karnataka Mangaluru Pan No.Aaava1252A Assessee Respondent Assessee By : Ms. Harsha J., A.R. Revenue By : Shri Parithivel, D.R. Date Of Hearing : 06.02.2024 Date Of Pronouncement : 06.02.2024 O R D E R Per Chandra Poojari: This Appeal By Assessee Is Directed Against Order Of Nfac For The Assessment Year 2017-18 Dated 12.9.2023 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). The Assessee Has Raised Following Grounds Of Appeal: 1. “The Order Of The Learned Commissioner Passed Under Section 250 Of The Act Is Opposed To Law, Equity, Weight Of Evidence, Probabilities & The Facts & Circumstances In The Appellant'S Case. 2. The Appellant Denies To Be Assessed To Tax On Total Income As Determined By The Learr.Ad Ao Of Rs. 2,52,38,729/- As Against The Total Income Reported By The Appellant Of Rs. Nil On The Facts & Circumstances Of The Case.

For Appellant: Ms. Harsha J., A.RFor Respondent: Shri Parithivel, D.R

Section 250Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

Date of Pronouncement : 06.02.2024 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by assessee is directed against order of NFAC for the assessment year 2017-18 dated 12.9.2023 passed u/s 250 of the Income Tax Act, 1961 (in short “The Act”). The assessee has raised following

Anshul Dewat Singhal, Mumbai vs. Income Tax Officer-34(1)(1), Mumbai

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

ITA 3427/MUM/2023[2013-14]Status: DisposedITAT Mumbai06 Feb 2024AY 2013-14

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: MS. Vinita Shah, CAFor Respondent: Shri Manoj Kumar Sinha, Sr. DR

Section 142(1)Section 144

Pronouncement O R D E R Per Padmavathy S, AM: This appeal is against the order of the Commissioner of Income Tax (Appeals) / NFAC [for short 'the CIT(A)] dated 17.01.2023 for the AY 2013-14. The assessee raised the following grounds of appeal: “1. On the facts and circumstances

Nitco Paints Pvt Ltd, Mumbai vs. DCIT-Circle 5(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2912/MUM/2023[2018-19]Status: DisposedITAT Mumbai06 Feb 2024AY 2018-19

Bench: Shri Kuldip Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Vimal Punmiya &For Respondent: Shri Ashok Kumar Ambastha

Section 234ASection 270ASection 801A(4)(iv)Section 80I

Pronouncement O R D E R Per Padmavathy S, AM: This appeal is against the order of the Commissioner of Income Tax (Appeals) / NFAC [for short 'the CIT(A)] dated 01.12.2022 for the AY 2018-19. The assessee raised the following grounds of appeal: “1. On the facts and circumstances

Staark Accessories Private Limited, Mumbai vs. ACIT, Circle 13(2)(2)

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

ITA 2418/MUM/2023[2016-17]Status: DisposedITAT Mumbai06 Feb 2024AY 2016-17

Bench: Shri Kuldip Singh & Shri Gagan Goyalm/S. Staark Accessories Pvt. Ltd., A-20, Virwani Industrial Estate Goregaon East, Mumbai- 400063, Pan: Aatcs1816J ...... Appellant Vs. Acit-13(2) (2), Aayakar Bhavan, Maharishi Karve Road, Mumbai- 400020 ..... Respondent

For Appellant: Shri Ashwin S. Chhag, Ld. ARFor Respondent: Shri Prasoon Kabra, Ld. DR

Section 143(2)Section 143(3)Section 145Section 250Section 44A

06/02/2024 O R D E R PER GAGAN GOYAL, A.M: This appeal by assessee is directed against the order of National Faceless Appeal Centre (NFAC), Delhi dated 02.05.2023 u/s. 250 of the Income Tax Act, 1961 (in short ‘the Act’) for A.Y. 2016-17. The assessee has raised the following ... making disallowance salary paid to its employees to the tune of Rs.1,41,59,519/- in view of insufficient evidences which Ld. NFAC has confirmed. Aggrieved by which the appellant is before this Hon'ble Tribunal with the following grounds of appeal; 1. Both the lower authorities have failed

Asstt. Commissioner of Income Tax Circle 6(1)(2), Mumbai vs. M/S Island Star Mall Developers Pvt Ltd, Mumbai

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

ITA 2357/MUM/2023[2017-18]Status: DisposedITAT Mumbai06 Feb 2024AY 2017-18

Bench: Shri Br Baskaran & Shri Pavan Kumar Gadale

Bench: These are the cross appeals filed by the assessee and the revenue against the common order of the National Faceless Appeal Centre (NFAC), Delhi / CIT(A) passed u/sec 250 of the Act. 2. Since the issues involved in these appeals are common, identical and interlinked, hence they are clubbed ... interest should be set-off against the project cost however, there is no clear-cut fact finding with quantification by the Ld. CIT(A) / NFAC as to how much interest need be capitalized in the instant case for the current year and how much is to be treated as revenue