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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

Sabbirbhai Abdeali Gangardiwala, Dahod vs. ITO Ward 01 Dahod, Dahod

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

ITA 1519/AHD/2025[2019-2020]Status: DisposedITAT Ahmedabad19 Jan 2026AY 2019-2020

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 1519/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2019-20) बनाम/ Sabbirbhai Abdeali Income Tax Officer Gangardiwala Ward-01, Dahod Vs. H. No.1428, Hamidi Mohalla Taiwala, Dahod, Gujarat-389151 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Achpg4301R (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : None ""यथ" क" ओर से/Respondent By : Smt. Mamta Singh, Sr. Dr 13/01/2026 Date Of Hearing Date Of Pronouncement 19/01/2026 O R D E R The Present Appeal Has Been Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Hereinafter Referred To As “Nfac”), Delhi (Hereinafter Referred To As “Cit(A)”) Dated 31.05.2025 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As The “Act”) & Relates To Assessment Year (A.Y.) 2019-20. 2. The Grounds Of Appeals Raised By The Assessee Are As Under:

For Appellant: NoneFor Respondent: Smt. Mamta Singh, Sr. DR
Section 250Section 68

been filed by the Assessee against the order of the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (hereinafter referred to as “NFAC”), Delhi (hereinafter referred to as “CIT(A)”) dated 31.05.2025 passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred

Mangalabai Vijaykumar Sahuji (Deceased) Through Legal Heir (Son) Rahul Vijaykumar Sahuji, Aurangabad (Chhatrapati Sambhajinagar) vs. Income Tax Officer, Aurangabad (Chhatrapati Sambhajinagar)

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

ITA 2895/PUN/2025[2017-18]Status: DisposedITAT Pune19 Jan 2026AY 2017-18

Bench: Shri Manish Boradआयकर अपील सं. / Ita No.2895/Pun/2025 िनधा"रण वष" / Assessment Year : 2017-18 Mangalabai Vijaykumar Vs. Ito, Ward- 1(11), Sahuji (Deceased), Aurangabad. Through Legal Heir (Son) Rahul Vijaykumar Sahuji, A-13, Udyog Sadan, Midc, Railway Station, Aurangabad (Chhatrapati Sambhajinagar), Aurangabad- 431005. Pan : Awwps9047D Appellant Respondent Assessee By : Shri Pushpadant Vinod Sahuji (Virtual) Revenue By : Shri Shashank Ojha (Virtual) Date Of Hearing : 13.01.2026 Date Of Pronouncement : 19.01.2026 आदेश / Order Per Manish Borad, Am: This Appeal Filed At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A)/Nfac Dated 13.10.2025 Which Is Arising Out Of The Assessment Order U/S 143(3) Of The Act For Assessment Year 2017-18 Framed On 24.12.2019 By The Ito, Ward- 1(11), Aurangabad. 2. I Note That The Assessee Has Raised As Many As 29 Grounds Of Appeal Raising Various Legal Issues As Well As Grounds On Merits

For Appellant: Shri Pushpadant Vinod Sahuji (Virtual)For Respondent: Shri Shashank Ojha (Virtual)
Section 143(2)Section 143(3)Section 250(6)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “SMC”, PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER आयकर अपील सं. / ITA

Capgemini Technology Services India Limited (Successor to Liquidhub India Private Limited), Pune vs. Assistant Commissioner of Income Tax, Circle 1(1), Pune

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

ITA 2753/PUN/2025[2020-21]Status: DisposedITAT Pune19 Jan 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2753/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Capgemini Technology V Assessment Unit, Services India S Income Tax Limited(Successor To Liquid Department. Hub India Private Limited), Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase Iii, Midc Sez, Village Man, Taluka Mulshi, District Pune – 411057. Pan: Aaacl8943J Appellant/ Assessee Respondent /Revenue Assessee By Shri Sudin Sabnis & Shri Siddhesh Khandalkar Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 05/01/2026 Date Of Pronouncement 19/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2020-21 Dated 02.09.2025 Emanating From The Penalty Order Passed Under Section

Section 115JSection 143(3)Section 155Section 155(18)Section 18Section 250Section 270ASection 270A(6)(a)Section 40

ORDER PER DR. DIPAK P. RIPOTE, AM: This is an appeal filed by the Assessee against the order of ld.Commissioner of Income Tax(Appeal)[NFAC], passed under section 250 of the Income Tax Act, 1961 for the A.Y.2020-21 dated 02.09.2025 emanating from the Penalty Order passed under section ITA No.2753/PUN/2025 ... penal consequences u/s 270A, if claim for deduction u/s 40(a)(ii) was suo-moto withdrawn - Global Coal and Mining Pvt. Ltd. v. NFAC [ITA No. 2682/Del/2024) vii. Pertaining to non-applicability of penal consequences in case more than one interpretation was possible-CIT v Calcutta Credit Corporation

Cil Employees Co Op Credit Society Limited, Pune vs. Exemption, Ward-1(2), Pune

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

ITA 1600/PUN/2025[2020-21]Status: DisposedITAT Pune19 Jan 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1600/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Cil Employees’ Co Op Credit V Exemption, Society Limited, S Ward-1(2), Pune. Cummins Inida Ltd., Kothrud, Pune – 411038. Pan:Aabac8908M Appellant / Assessee Respondent / Revenue Assessee By Shri Kishore Phadke Revenue By Shri Sandeep Sathe – Jcit Date Of Hearing 08/12/2025 Date Of Pronouncement 19/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2020-21 Dated 29.02.2024 Emanating From The Assessment Order Passed Under Section 143(3) Read With Section 144B Of The I.T .Act, 1961 Dated 28.09.2022. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(1)Section 143(3)Section 144BSection 250Section 80PSection 80P(2)(a)Section 80P(2)(b)Section 80P(2)(d)Section 80P(4)

19/01/2026 आदेश/ ORDER PER DR. DIPAK P. RIPOTE, AM: This appeal filed by the Assessee against the order of ld.Commissioner of Income Tax(Appeal)[NFAC], passed under section 250 of the Income Tax Act, 1961 for A.Y.2020-21 dated 29.02.2024 emanating from the Assessment Order passed under section 143(3) read ... dated 28.09.2022. The Assessee has raised the following grounds of appeal : ITA No.1600/PUN/2025 [A] “1. The learned CIT(A)-NFAC erred in law and facts in enhancing the income of the appellant to Rs.1,78,37,072/-in place of the income determined by the Ld. AO of Rs.4

Gunmala Devi Jain, Kolkata vs. D.C.I.T., Circle - 29, Kolkata

ITA 14/KOL/2025[2015-2016]Status: DisposedITAT Kolkata19 Jan 2026AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Gunmala Devi Jain…..……..……..……….………….……….……….……Appellant 401, Wing-B, Windsor Palace, 6A Iron Side Road, Ballygunge, Kol-700019.. [Pan: Acrpj8161E] Vs. Dcit, Circle-29, Kolkata……………………………..…….....……...…..…..Respondent Appearances By: Shri Miraj D Shah, Ar Appeared On Behalf Of The Appellant. Shri Sandeep Kr. Mehta, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 06, 2026 Date Of Pronouncing The Order : January 19, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.05.2024 Of The Nfac, Delhi (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2015–16. 2. The Appeal Has Been Filed By The Assessee With A Delay Of 156 Days & The Assessee Has Filed A Petition For Condonation Of The Delay. After Going Over The Said Petition, We Find Sufficient Reasons Behind The Delay Which Are Beyond The Control Of The Assessee & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 143(3)Section 250Section 54Section 57

ORDER Per Pradip Kumar Choubey, Judicial Member: This appeal filed by the assessee is directed against the order dated 30.05.2024 of the NFAC, Delhi (hereinafter referred to as the “CIT(A)”) passed u/s 250 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) for the assessment year

M/S. Annleela Vinimay (P) Ltd., Kolkata vs. I.T.O., Ward - 4(3), Kolkata

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

ITA 1275/KOL/2024[2017-2018]Status: DisposedITAT Kolkata19 Jan 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1275/Kol/2024 Assessment Year: 2017-18 M/S Annleela Vinimay (P) Ltd..………………....…………………....Appellant 413, Panchanantala Road, Paschim Putiary, Ground Floor, Megh Manasi Apartment, Kol-41.. [Pan: Aacca2542E] Vs. Ito, Ward-4(3), Kolkata..……………....…..………………….…..... Respondent Appearances By: Shri Rajeeva Kumar, Ar., Appeared On Behalf Of The Appellant. Shri Dheeraj, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 19, 2026 Date Of Pronouncing The Order : January 19, 2026 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Ld. Cit(A)”) Dated 12.04.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed Return Of Income Declaring A Total Income Of ₹1,24,165. The Assessing Officer Completed Assessment U/S 144 By Making Addition Of Rs.5,13,68,152/-. 3. Aggrieved By The Assessment Order, The Assessee Preferred An Appeal Before The Cit(A). However, The Appeal Was Dismissed For Non- Submission Of Audit Report.

Section 144Section 250

order : January 19, 2026 आदेश / ORDER Per Sonjoy Sarma, Judicial Member: This appeal filed by the assessee is directed against the order of the NFAC, Delhi (hereinafter referred to as “ld. CIT(A)”) dated 12.04.2024 passed under Section 250 of the Income-tax Act, 1961 (hereinafter referred