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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

Geeta Devi Sharma, Jaipur vs. ITO Ward 6(4), Jaipur

ITA 396/JPR/2022[2012-13]Status: DisposedITAT Jaipur17 Jan 2024AY 2012-13

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Mahendra Gargieya, AdvocateFor Respondent: Smt. Monisha Choudhary, Addl. CIT
Section 144Section 147Section 148Section 234A

assessee is directed against order of the ld. CIT(A) dated 09-09-2022, National Faceless Appeal Centre, Delhi [ hereinafter referred to as (NFAC) ] for the assessment year 2012-13 wherein the assessee has raised the following grounds of appeal. 1.1. The very action taken u/s 147 r.w.s

Shri. Anand, Bangalore vs. Income-Tax Officer, Ward-3(2)(4), Bangalore

In the result, appeal of the assessee in ITA No

ITA 999/BANG/2023[2012-13]Status: DisposedITAT Bangalore17 Jan 2024AY 2012-13

Bench: Shri George George K. & Shri Chandra Poojari

For Appellant: Shri R. Chandrashekar, A.RFor Respondent: Shri Subramanian S., D.R
Section 131Section 144Section 147Section 148Section 271Section 271(1)(c)Section 274

1001/Bang/2023 and ITA No.1144/Bang/2023 are emanated from the different orders of CIT(A) for the assessment years 2011-12 to 2015-16, wherein NFAC has confirmed the levy of penalty u/s 271(1)(c) of the Income Tax Act, 1961 (in short “The Act”). 2. The assessee has raised common ... these cases. Since we have quashed the penalty orders itself, we refrain from going into the merit in sustaining the penalty by NFAC. Accordingly, appeals of the assessee in ITA Nos.998 to 1001 & 1144/Bang/2023 are allowed. ITA No.1002/Bang/2023 (AY 2017-18): 5. Facts of the issue are that Assessee

Sri. Anand, Bangalore vs. Income-Tax Officer, Ward-3(2)(4), Bangalore

In the result, appeal of the assessee in ITA No

ITA 998/BANG/2023[2011-12]Status: DisposedITAT Bangalore17 Jan 2024AY 2011-12

Bench: Shri George George K. & Shri Chandra Poojari

For Appellant: Shri R. Chandrashekar, A.RFor Respondent: Shri Subramanian S., D.R
Section 131Section 144Section 147Section 148Section 271Section 271(1)(c)Section 274

1001/Bang/2023 and ITA No.1144/Bang/2023 are emanated from the different orders of CIT(A) for the assessment years 2011-12 to 2015-16, wherein NFAC has confirmed the levy of penalty u/s 271(1)(c) of the Income Tax Act, 1961 (in short “The Act”). 2. The assessee has raised common ... these cases. Since we have quashed the penalty orders itself, we refrain from going into the merit in sustaining the penalty by NFAC. Accordingly, appeals of the assessee in ITA Nos.998 to 1001 & 1144/Bang/2023 are allowed. ITA No.1002/Bang/2023 (AY 2017-18): 5. Facts of the issue are that Assessee

Ambika Ghorpade, Bellary vs. Assistant Commissioner of Income-Tax, Circle-1, Bellary

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

ITA 906/BANG/2023[2014-15]Status: DisposedITAT Bangalore17 Jan 2024AY 2014-15

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2014-15

For Appellant: Shri K.R. Pradeep & Ms. Girija G., A.RsFor Respondent: Shri Subramanian S., D.R
Section 14ASection 250Section 37(1)

Date of Pronouncement : 17.01.2024 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by assessee is directed against order of NFAC for the assessment year 2014-15 dated 10.10.2023 passed u/s 250 of the Income Tax Act, 1961 (in short “The Act”). 2. The first ground ... carry on Mining operation. According to ld. AO, assessee has not incurred expenditure wholly and exclusively for the purpose of business. However, the NFAC noted that assessee has not substantiated its expenditure and disallowed the same and the same has been confirmed by the NFAC. 4.2 Before

M/S. Panjos Builders Pvt Ltd., Bangalore vs. Income Tax Officer, Ward-5(1)(1), Bangalore

In the result, appeal of the assessee is allowed

ITA 434/BANG/2023[2007-08]Status: DisposedITAT Bangalore17 Jan 2024AY 2007-08

Bench: Shri Chandra Poojari & Smt. Madhumita Royassessment Year: 2007-08

For Appellant: Shri Ravishankar, A.RFor Respondent: Shri V. Parithivel, D.R
Section 147Section 148Section 201(1)Section 234ASection 250Section 40Section 4o

Date of Pronouncement : 17.01.2024 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by assessee is directed against order of NFAC for the assessment year 2007-08 dated 26.3.2022 passed u/s 250 of the Income Tax, 1961 (in short “The Act”). The assessee has raised following grounds ... appeal: The order passed by the Commissioner of Income Tax (Appeals), NFAC, Delhi, passed under section 250 of the Income Tax Act, 1961 (hereafter "the Act") is in so far as it is against the appellant is opposed to law, equity, weight of evidence, probabilities, facts and circumstances

Shri. Anand, Bangalore vs. Income-Tax Officer, Ward-3(2)(4), Bangalore

In the result, appeal of the assessee in ITA No

ITA 1144/BANG/2023[2013-14]Status: DisposedITAT Bangalore17 Jan 2024AY 2013-14

Bench: Shri George George K. & Shri Chandra Poojari

For Appellant: Shri R. Chandrashekar, A.RFor Respondent: Shri Subramanian S., D.R
Section 131Section 144Section 147Section 148Section 271Section 271(1)(c)Section 274

1001/Bang/2023 and ITA No.1144/Bang/2023 are emanated from the different orders of CIT(A) for the assessment years 2011-12 to 2015-16, wherein NFAC has confirmed the levy of penalty u/s 271(1)(c) of the Income Tax Act, 1961 (in short “The Act”). 2. The assessee has raised common ... these cases. Since we have quashed the penalty orders itself, we refrain from going into the merit in sustaining the penalty by NFAC. Accordingly, appeals of the assessee in ITA Nos.998 to 1001 & 1144/Bang/2023 are allowed. ITA No.1002/Bang/2023 (AY 2017-18): 5. Facts of the issue are that Assessee

Vinay Sureshbabu Illur, Bagalkot vs. Income Tax Officer, Ward 1, Bagalkot

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

ITA 1118/BANG/2023[2017-18]Status: DisposedITAT Bangalore17 Jan 2024AY 2017-18

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2017-18

For Appellant: Smt. Preethi S. Patel, A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Revenue
Section 143(3)

Date of Pronouncement : 17.01.2024 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by assessee is against the order of NFAC for the assessment year 2017-18 dated 10.11.2023. 2. In this case, assessment order u/s 143(3) of the Income Tax Act, 1961 (in short ... vide order dated 10.11.2023 has dismissed the appeal of the assessee for not prosecuting the same before NFAC. Against this assessee is in appeal before us. 3. Before us, ld. A.R. submitted that assessee is not well versed in Income Tax Portal and failed to notice about the notice issued

Town Vividoddesha Sahakari Bhandara Niyamitha, Tumkuru vs. Income Tax Officer, Ward-1 & Tps, Tumkur

In the result, the assessee’s appeal is allowed

ITA 1089/BANG/2023[2014-15]Status: DisposedITAT Bangalore17 Jan 2024AY 2014-15

Bench: Shri George George K. & Shri Chandra Poojariassessment Year : 2014-15

For Appellant: Shri Sandeep Chalapathy, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 143(2)Section 143(3)Section 154Section 154(3)Section 80P

George George K., Vice President This appeal is filed by the assessee against the order of the CIT(Appeals), National Faceless Appeal Centre, Delhi [NFAC] dated 18.10.2023 for the assessment year 2014-15. 2. The solitary issue that is raised is whether the CIT(Appeals) is justified in confirming

Shri. Anand, Bangalore vs. Income-Tax Officer, Ward-3(2)(4), Bangalore

In the result, appeal of the assessee in ITA No

ITA 1002/BANG/2023[2017-18]Status: DisposedITAT Bangalore17 Jan 2024AY 2017-18

Bench: Shri George George K. & Shri Chandra Poojari

For Appellant: Shri R. Chandrashekar, A.RFor Respondent: Shri Subramanian S., D.R
Section 131Section 144Section 147Section 148Section 271Section 271(1)(c)Section 274

1001/Bang/2023 and ITA No.1144/Bang/2023 are emanated from the different orders of CIT(A) for the assessment years 2011-12 to 2015-16, wherein NFAC has confirmed the levy of penalty u/s 271(1)(c) of the Income Tax Act, 1961 (in short “The Act\u201d). 2. The assessee has raised ... these cases. Since we have quashed the penalty orders itself, we refrain from going into the merit in sustaining the penalty by NFAC. Accordingly, appeals of the assessee in ITA Nos.998 to 1001 & 1144/Bang/2023 are allowed. ITA No.1002/Bang/2023 (AY 2017-18): 5. Facts of the issue are that Assessee

Shri. Anand, Bangalore vs. Income-Tax Officer, Ward-3(2)(4), Bangalore

In the result, appeal of the assessee in ITA No

ITA 1001/BANG/2023[2015-16]Status: DisposedITAT Bangalore17 Jan 2024AY 2015-16

Bench: Shri George George K. & Shri Chandra Poojari

For Appellant: Shri R. Chandrashekar, A.RFor Respondent: Shri Subramanian S., D.R
Section 131Section 144Section 147Section 148Section 271Section 271(1)(c)Section 274

1001/Bang/2023 and ITA No.1144/Bang/2023 are emanated from the different orders of CIT(A) for the assessment years 2011-12 to 2015-16, wherein NFAC has confirmed the levy of penalty u/s 271(1)(c) of the Income Tax Act, 1961 (in short “The Act”). 2. The assessee has raised common ... these cases. Since we have quashed the penalty orders itself, we refrain from going into the merit in sustaining the penalty by NFAC. Accordingly, appeals of the assessee in ITA Nos.998 to 1001 & 1144/Bang/2023 are allowed. ITA No.1002/Bang/2023 (AY 2017-18): 5. Facts of the issue are that Assessee

Shri. Anand, Bangalore vs. Income-Tax Officer, Ward-3(2)(4), Bangalore

In the result, appeal of the assessee in ITA No

ITA 1000/BANG/2023[2014-15]Status: DisposedITAT Bangalore17 Jan 2024AY 2014-15

Bench: Shri George George K. & Shri Chandra Poojari

For Appellant: Shri R. Chandrashekar, A.RFor Respondent: Shri Subramanian S., D.R
Section 131Section 144Section 147Section 148Section 271Section 271(1)(c)Section 274

1001/Bang/2023 and ITA No.1144/Bang/2023 are emanated from the different orders of CIT(A) for the assessment years 2011-12 to 2015-16, wherein NFAC has confirmed the levy of penalty u/s 271(1)(c) of the Income Tax Act, 1961 (in short “The Act”). 2. The assessee has raised common ... these cases. Since we have quashed the penalty orders itself, we refrain from going into the merit in sustaining the penalty by NFAC. Accordingly, appeals of the assessee in ITA Nos.998 to 1001 & 1144/Bang/2023 are allowed. ITA No.1002/Bang/2023 (AY 2017-18): 5. Facts of the issue are that Assessee

Bhalchandra P. Dalvi, Ghahtkopar, Mumbai vs. ITO, Ward 27 (1) (2), Vashi, Navi Mumbai

In the result the appeal filed by the assessee is allowed

ITA 2492/MUM/2023[2008-09]Status: DisposedITAT Mumbai17 Jan 2024AY 2008-09

Bench: Shri Om Prakash Kant & Shri Pavan Kumar Gadalebhalchandra P. Dalvi, Vs. Ito-Ward 27(1)(2), 1, Hemalaya Society, It-Office, Vashi Milind Nagar, Near Railway Station Sungrace English Building, School,Ghatkopar(W), Navimumbai-400705. Mumbai-400084. Pan/Gir No. : Aampd3092P Appellant .. Respondent Appellant By : Shri. Dinesh R.Shah & Shri B.R.Vyas.Ar Respondent By : Shri.Ashokkumarambastha,Sr.Dr Date Of Hearing 21.12.2023 Date Of Pronouncement 17.01.2024 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac) Delhi / Cit(A) Passed U/Sec271D & U/Sec250 Of The Act. 1. The Learned Joint Commissioner Of Income Tax 27(1) Erred In Levying Penalty U/S 271D Amounting To Rupees 24,50,000/- Rupees Twenty Four Lakhs Fifty Thousand As Well As Cit(A) National Faceless Appeal Centre (Nfac) Erred In Confirming The Same. Bhalachandra P. Dalvi.Mumbai. 2.1 The Appellant Has Received Rupees 18,50,000/- Rupees Eighteen Lakhs Fifty Thousand Cash Against Sale Of Flat & Rs.6,00,000/- Amount Raised From Lenders Which Amount Was Less Than Rupees Twenty Thousand Out Of Rupees Six Lakhs, Rupees Four Lakhs Seventy Five Thousand Is Already Taxed As Income & Balance Loans Are Accepted As Genuine & Each Loans Less Than Rs.20,000/- Considering Above Facts & Circumstances No Penalty U/S 271D Can Be Levied & Same Be Deleted.

For Appellant: Shri. Dinesh R.Shah & ShriFor Respondent: Shri.AshokKumarAmbastha,Sr.DR
Section 143(3)Section 147Section 271Section 271D

PAVAN KUMAR GADALE JM: The appeal is filed by the assessee against the order of the National Faceless Appeal Centre (NFAC) Delhi / CIT(A) passed u/sec271D and U/sec250 of the Act. 1. The Learned Joint Commissioner of Income Tax 27(1) erred in levying penalty u/s 271D amounting to Rupees ... Rupees twenty four Lakhs fifty thousand as well as CIT(A) National Faceless Appeal Centre (NFAC) erred in confirming the same. Bhalachandra P. Dalvi.Mumbai. 2.1 The Appellant has received rupees 18,50,000/- Rupees Eighteen Lakhs fifty thousand cash against sale of flat and Rs.6,00,000/- amount raised from

Assistant Comm. of Income Tax Circle-3, Thane vs. Rajmohan Appalacharya N. Chakravarty, Mumbai

In the result, the appeal stands dismissed and the cross objection is disposed off as not maintainable

ITA 2120/MUM/2023[2018-2019]Status: DisposedITAT Mumbai17 Jan 2024AY 2018-2019

Bench: Justice (Retd.) C.V. Bhadang & Shri B.R. Baskaran: A.Y : 2018-19 Assistant Commissioner Of Income Vs. Rajmohan Appalacharya N. Tax, Circle-3, Thane. Chakravarty (Appellant) 5/52, Garden Estate, Opp. Pokhran Road No. 1, Thane 400 601. (Respondent) Pan : Abzpn2092B

For Appellant: Shri S.V. ApteFor Respondent: Smt. Mahita Nair
Section 143(2)Section 69

short), which in turn arose out of order dated 25.08.2021 passed by the DCIT, 2 ITA 2120/Mum/2023 & CO 118/MUM/2023 Rajmohan Appalacharya N. Chakravarty NFAC, Delhi (hereinafter referred to as ‘AO’) for the assessment year 2018- 19. 2. The brief facts are that the respondent-assessee is the Director

Brigs Trading Co. P.Ltd, Mumbai vs. ACIT Cir 6(1), Mumbai

ITA 2270/MUM/2014[2009-10]Status: DisposedITAT Mumbai17 Jan 2024AY 2009-10

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Dcit, Cir 6(1), R.No. 506, 5Th Floor, Aayakar Bhavan, M.K. Road, Mumbai-20. Appellant

Section 143(3)Section 14ASection 36Section 36(1)(vii)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAHUL

Brigs Trading Co. P.Ltd, Mumbai vs. ACIT Cir 6(1), Mumbai

ITA 2269/MUM/2014[2008-09]Status: DisposedITAT Mumbai17 Jan 2024AY 2008-09

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Respondent: Mr. Dalpat Shah & Mr. B.S. Sharma
Section 143(3)Section 14ASection 36Section 36(1)(vii)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAHUL

DCIT Cir 6(1), Mumbai vs. Briggs Trading Co, P. Ltd, Mumbai

ITA 2136/MUM/2014[2008-09]Status: DisposedITAT Mumbai17 Jan 2024AY 2008-09

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

For Appellant: Mr. Dalpat Shah & Mr. B.S. SharmaFor Respondent: Mr. Ujjawal Kumar Chavan, Sr. DR
Section 143(3)Section 14ASection 36Section 36(1)(vii)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAHUL

Amit Kumar Bhardwaj, Meerut vs. ITO, Ward-58(2), Delhi

In the result, the appeal of the assessee is allowed

ITA 3494/DEL/2023[2016-17]Status: DisposedITAT Delhi17 Jan 2024AY 2016-17

Bench: Shri M. Balaganeshamit Kumar Bhardwaj, Vs. Ito, 282, Boundary Road, Ward-58(2), Civic Line Meerut, Uttar Delhi Pradesh Pan: Ajopb9557C Assessee By : Shri Vinod Kumar Goel, Adv Revenue By: Shri Om Prakash, Sr. Dr Date Of Hearing 17/01/2024 Date Of Pronouncement 17/01/2024

For Appellant: Shri Vinod Kumar Goel, AdvFor Respondent: Shri Om Prakash, Sr. DR
Section 144Section 50C

pronouncement 17/01/2024 O R D E R 1. The appeal in ITA No.3494/Del/2023 arises out of the order of National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as „ld. CIT(A)‟, in short] in Appeal No. ITBA/NFAC/S/250/2023-24/1058123488(1) dated 22.11.2023 against the order of assessment passed u/s 144 dated

Paytm First Games Private Limited, Delhi vs. DCIT, Circle-19(1), Delhi

In the result, the Appeal of the assessee is allowed

ITA 329/DEL/2023[2020-21]Status: DisposedITAT Delhi17 Jan 2024AY 2020-21

Bench: Shri N.K.Billaiya & Shri Yogesh Kumar U.S.

Section 139(1)Section 139(4)Section 139(5)Section 143(1)

brought forward loss of Rs. 1,26,29,71,402/-. Aggrieved by the said intimation dated 07/09/2021, the assessee preferred an Appeal before the NFAC (CIT(A), the Ld. CIT(A) affirmed the said disallowance made by the A.O. vide order dated 21/12/2022. Aggrieved by the order

Ganesh Builders Private Limited, New Delhi vs. Income Tax Officer, C. R. Building, Delhi

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

ITA 2857/DEL/2023[2012-13]Status: DisposedITAT Delhi17 Jan 2024AY 2012-13

Bench: the Ld. AO that it had not received any such sum of Rs.19,00,000/- from M/s Shubh Supplier Ltd. or any other company controlled by Sh. Beni Prasad Lahotia. In respect of this contention, the assessee also enclosed the complete bank statements for the perusal of the Ld. AO. The Ld. AO, however did not heed to this factual contention of the assessee and proceeded to treat the sum of Rs.19,00,000/- as unexplained cash credits u/s 68 of the Act in the hands of the assessee.

Section 143(1)Section 143(3)Section 68

17/01/2024 ORDER This appeal of the Assessee arises out of the order of the Learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘Ld. CIT(A)’] in DIN & Order No. ITBA/NFAC/S/250/2023- 24/1055401824(1) dated 24/08/2023 against the order passed by Income Tax Officer

River Heights Phase-1 Association of Apartment Owner, Ghaziabad vs. ITO, Ward - 2(2)(2), Ghaziabad

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

ITA 2801/DEL/2023[2017-18]Status: DisposedITAT Delhi17 Jan 2024AY 2017-18

Bench: the Ld. AO which enabled the Ld. AO to add the entire cash River Heights Phase-1 Association of Apartment Owner vs. ITO

Section 142(1)Section 144

17/01/2024 ORDER This appeal of the Assessee arises out of the order of the Learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘Ld. CIT(A)’] in DIN & Order No. ITBA/NFAC/S/250/2023- 24/105495345(1) dated 08/08/2023 against the order passed by Income Tax Officer