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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

Shri Sidhdata Steel Tubes, Delhi vs. ITO- Ward-59(3), Delhi

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

ITA 2525/DEL/2022[2008-09]Status: DisposedITAT Delhi09 May 2023AY 2008-09

Bench: Sh. N. K. Billaiya & Ms. Astha Chandraassessment Year: 2008-09 Shri Sidhata Steel Tubes Ito C/O Rajat Gupta 12-A, Kh Vs Ward- 59 (3) No.12/23, Sewa Dham Road, Delhi Mandoli Industries Area, New Delhi-110093 Pan No.Aaofs3736K (Appellant) (Respondent)

Section 143(3)

hearing: 09/05/2023 Date of Pronouncement: 09/05/2023 ORDER PER N. K. BILLAIYA, AM: This appeal by the assessee is preferred against the order of the NFAC, Delhi dated 17.08.2022 pertaining to A.Y.2008-09. 2. The substantive grievance of the assessee is that the CIT(A)/NFAC erred in passing the order exparte

Agrasar Education Pvt Ltd, New Delhi vs. ITO, Ward 1(1) Faridabad, Faridabad

In the result, the appeal of the assessee is allowed

ITA 2362/DEL/2022[2017-18]Status: DisposedITAT Delhi09 May 2023AY 2017-18

Bench: Shri C.M. Garg & Shri M. Balaganeshassessment Year: 2017-18 Agrasar Education Ltd., Vs Ito, Ipso Legal H-35, 1St Floor, Ward 1(1), Jangpura Extension, Faridabad. New Delhi – 110 014. Pan: Aalca0777A

For Appellant: Shri Dishant Sethi, AdvocateFor Respondent: Shri Raghunath, Sr. DR
Section 142(1)Section 144Section 272A(1)(d)

appeal in ITA No.2362/Del/2022 for AY 2017-18 arises out of the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, [hereinafter referred to as ‘ld. CIT(A)’, in short] in DIN & Order No.ITBA/NFAC/S/250/2022-23/1045445945(1) dated 13.09.2022 against the order of assessment passed u/s 272A ... assessee at Rs 46,02,740/- as against the returned income of Rs 1,02,740/-. 4. Before the ld. CIT(A) NFAC, it was submitted that on 09.10.2019, the assessee had sought some time in electronic mode by requesting in income tax portal, to furnish the requisite details

Skg Engineering Pvt Ltd., New Delhi vs. DCIT, Circle 23(2), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1293/DEL/2021[2017-18]Status: DisposedITAT Delhi09 May 2023AY 2017-18

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2017-18 Skg Engineering Pvt. Ltd., Vs Dcit, Gripwel House, Block-5, Circle 23(2), Sector-C 6&7, New Delhi. Lsc Vasant Kunj, New Delhi – 110 070. Pan: Aaacs3743F (Applicant) (Respondent) Assessee By : Shri A.T. Panda, Advocate Revenue By : Ms Sapna Bhatia, Cit-Dr Date Of Hearing : 02.05.2023 Date Of Pronouncement : 09.05.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.1293/Del/2021 For Ay 2017-18 Arises Out Of The Order Of The National Faceless Appeal Centre (Nfac), Delhi, In Din & Order No.Itba/Nfac/S/250/2021-22/1034916910(1) Dated 17.08.2021 [Hereinafter Referred To As ‘Ld. Cit(A)’, In Short] Against The Order Of Assessment Passed U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 12.12.2019 By The Ld. Income-Tax Officer, Circle 23(2), Delhi (Hereinafter Referred To As ‘Ld. Ao’).

For Appellant: Shri A.T. Panda, AdvocateFor Respondent: Ms Sapna Bhatia, CIT-DR
Section 143(3)Section 14ASection 14A(3)

BALAGANESH, AM: This appeal in ITA No.1293/Del/2021 for AY 2017-18 arises out of the order of the National Faceless Appeal Centre (NFAC), Delhi, in DIN & Order No.ITBA/NFAC/S/250/2021-22/1034916910(1) dated 17.08.2021 [hereinafter referred to as ‘ld. CIT(A)’, in short] against the order of assessment passed

Ranjitbhai Dhayabhai Panchal, Na vs. Arivs.Income Tax Officer, Navsari Circle, Navsari

In the result, the ground of appeal raised by the assessee is allowed

ITA 266/SRT/2022[2017-18]Status: DisposedITAT Surat09 May 2023AY 2017-18

Bench: SHRI PAWAN SINGH (Judicial Member)

Section 10(2)Section 143(3)Section 254(1)Section 56(2)Section 56(2)(VII)Section 56(2)(vii)

assessee has raised the following grounds of appeal:- “1. The Learned AO as well as the Learned CIT(A)/National Faceless Appeal Centre (NFAC) has erred in making addition Ranjitbhai D Panchal of Rs.18,00,000/- received as gift from assessee HUF which was exempted ... relative. Aggrieved by the additions in the assessment order, the assessee filed appeal before ld CIT(A). The appeal of assessee was migrated to NFAC, Delhi. The ld CIT(A) also confirmed the action order of assessing officer. Further aggrieved by the addition in the assessment order, the assessee filed

Sujatha Sudhakar Shetty, Mumbai vs. ITO-6(3)(4), Mumbai

ITA 635/MUM/2023[2012-13]Status: DisposedITAT Mumbai08 May 2023AY 2012-13
Section 143(1)Section 143(3)Section 147Section 148Section 234D

assessee’) by filing the present appeal, sought to set aside the impugned order dated 10.01.2023 passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’] qua the assessment order for Assessment year 2012-13 on the grounds inter-alia that:- “1. The Commissioner

Basic Chemicals Cosmetics & Dyes Export Promotion Council, Mumbai vs. CIT(A) NFAC, Delhi

ITA 634/MUM/2023[2015-16]Status: DisposedITAT Mumbai08 May 2023AY 2015-16
Section 11Section 143(3)

assessee’) by filing the present appeal, sought to set aside the impugned order dated 28.12.2022 passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’] qua the assessment order for Assessment year 2015-16 on the ground inter-alia that:- “1. CIT(A) National

Mrs. Divyesh Ambalal Shah, Mumbai vs. ACIT-27(1), Navimumbai

ITA 629/MUM/2023[2011-12]Status: DisposedITAT Mumbai08 May 2023AY 2011-12
Section 143(3)Section 147Section 148Section 234BSection 68

assessee’) by filing the present appeal, sought to set aside the impugned order dated 03.01.2023 passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’] qua the assessment order for Assessment year 2011-12 on the grounds inter-alia that:- “1. The learned Commissioner

Parmatma Investments Pvt Ltd., Mumbai vs. ITO-3(2)(4), Mumbai

ITA 612/MUM/2023[2010-11]Status: DisposedITAT Mumbai08 May 2023AY 2010-11
Section 143Section 143(1)Section 147Section 14A

assessee’) by filing the present appeal, sought to set aside the impugned order dated 08.02.2023 passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’] qua the assessment order for Assessment year 2010-11 on the ground inter-alia that:- 2 “ 1.On the facts ... said M/s Integrated Masters Securities Pvt. Ltd. 3 On the facts and circumstances of the case and in law, the AO as well as NFAC (CIT(A)) did not provide information in respect of client code modification of Rs.31,25,085 to rebut the allegation made in the order

Oberoi Spring Co-Operative Housing Society Limited, Mumbai vs. ITO-24(3)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 598/MUM/2023[2016-2017]Status: DisposedITAT Mumbai08 May 2023AY 2016-2017

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

For Appellant: Shri Vijay MehtaFor Respondent: Shri Chetan Kacha
Section 142(1)Section 143(2)Section 143(3)Section 250Section 80PSection 80P(2)(d)Section 80P(4)

raised the following grounds:– Oberoi Spring Co–operative Housing Society Limited ITA no.598/Mum./2023 “1. Under the facts & circumstances of the case, the NFAC has erred in restricting deduction U/S 80P(2)(d) in respect of the interest received from Co- operative Bank to the extent to which deduction ... DIRECTLY CREDITED TO THE RESERVES IN THE BALANCE SHEET, is also eligible for deduction U/S 80P(2)(d). 2. Under the case, the NFAC has erred in NOT considering interest received from Co- operative Bank directly credited to Balance sheet aggregating to Rs.1

Shamshershah Pathan, Mumbai vs. ACIT, Circle-31(1), Mumbai

In the result, Appellant’s appeal stands allowed for statistical purposes

ITA 467/MUM/2023[2017-18]Status: DisposedITAT Mumbai08 May 2023AY 2017-18

Bench: Shri Om Prakash Kant & Shri Narender Kumar Choudhry: A.Y : 2017-18

For Appellant: Shri Ashok MehtaFor Respondent: Shri Anil Sant
Section 143(2)Section 143(3)Section 250Section 68

Assessee/Appellant herein against the order dated 10.01.2023 impugned herein passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (in short ‘Ld. Commissioner’) under Section 250 of the Income Tax Act, 1961 (in short ‘the Act’) pertaining to Assessment Year 2017-18. 2 Shamshershah Pathan

M/S Rosean Trading Company Limited, Mumbai vs. Income Tax Officer, TDS Ward 2(1)(3), Mumbai

In the result, appeal is allowed for statistical purpose

ITA 125/MUM/2023[2018-19]Status: DisposedITAT Mumbai08 May 2023AY 2018-19

Bench: Amit Shukla () & Ms. Padmavathy S. ()

Section 133BSection 201Section 201(1)

PADMAVATHY S. (AM) This appeal is against the order of the National Faceless Appeal Centre (NFAC) [hereinafter ‘Ld.CIT(A)’] dated 14/11/2022 for the assessment year 2018-19. The assessee raised the following grounds of appeal:- Ground 1; 1. On the facts and circumstances of the case

Diva Exports Pvt Ltd, Mumbai vs. Deputy Commissioner of Income Tax 9(3)(1), Mumbai

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

ITA 3218/MUM/2022[2014-2015]Status: DisposedITAT Mumbai08 May 2023AY 2014-2015

Bench: The Date Of Hearing.”

Section 143(1)Section 14ASection 271(1)Section 36(1)(iii)Section 37(1)

आदेश आदेश PER PADMAVATHY S. (A.M): This appeal against the order of learned national Faceless Appeal Centre, Delhi (herein after referred to “NFAC) dated 09.12.2022 for the assessment year 2014-15. 2. The assessee has raised following grounds of appeal:- “1. On the facts and in the circumstances

Amzen Technologies P.Ltd, New Delhi vs. ITO, Ward 2(3), New Delhi

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

ITA 192/DEL/2023[2011-12]Status: DisposedITAT Delhi08 May 2023AY 2011-12

Bench: Shri C.M. Gargamzen Technologies P. Ltd, Vs. Ito, 2, Lsc, Pamposh Enclave, Ward-2(3), Greater Kailash-I, New Delhi New Delhi (Appellant) (Respondent) Pan: Aajca1391A

For Appellant: Sh. V. Rajakumar, AdvFor Respondent: Sh. Om Prakash, Sr. DR
Section 250Section 6

This is an appeal filed by the assessee against the order of the ld CIT(A), National Faceless Appeal Centre (NFAC), Delhi dated 26.10.2022 for AY 2011-12. 2. The Ld. Sr. DR agreed to the contention of the authorities representative (AR) of the assessee that

Kamal Dixit, Haryana vs. AO Ward-2, Sonepat

In the result, appeal of the assessee is dismissed

ITA 846/DEL/2022[2018-19]Status: DisposedITAT Delhi08 May 2023AY 2018-19

Bench: Shri Saktijit Dey & Shri M. Balaganeshassessment Year: 2018-19 Kamal Dixit, Vs Ao, 240, Vpo-Bhainsra Wali, Ward-2, Ballabgarh, Sonepat. Faridabad, Haryana – 121 004. Pan: Astpd3725G (Applicant) (Respondent) Assessee By : None Revenue By : Shri Anuj Garg, Sr. Dr Date Of Hearing : 01.05.2023 Date Of Pronouncement : 08.05.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.846/Del/2022 For Ay 2018-19 Arises Out Of The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, [Hereinafter Referred To As ‘Ld. Cit(A)’, In Short] In Din & Order No.Itba/Nfac/S/250/2021-22/1035026042(1) Dated 23.08.2021 Against The Order Of Assessment Passed U/S 143(1) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 23.03.2020 By The Ld. Acit, Cpc (Hereinafter Referred To As ‘Ld. Ao’). 2. At The Outset, We Find That The Appeal Preferred By The Assessee Before Us Is Delayed By 189 Days. In View Of The Relaxation Provided By The Hon’Ble Supreme Court In The Light Of Covid 19 Pandemic, We Deem It Fit To Condone The Delay & Admit The Appeal For Adjudication.

For Appellant: NoneFor Respondent: Shri Anuj Garg, Sr. DR
Section 139(1)Section 143(1)Section 2(24)(x)Section 36(1)(iv)Section 36(1)(va)Section 43B

appeal in ITA No.846/Del/2022 for AY 2018-19 arises out of the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, [hereinafter referred to as ‘ld. CIT(A)’, in short] in DIN & Order No.ITBA/NFAC/S/250/2021-22/1035026042(1) dated 23.08.2021 against the order of assessment passed

Ganga Deep Medicare Services Private Limited, New Delhi vs. ACIT Circle-10(1), New Delhi

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

ITA 425/DEL/2021[2017-18]Status: DisposedITAT Delhi08 May 2023AY 2017-18

Bench: Shri N.K. Billaiya & Shri Anubhav Sharma

For Appellant: Shri Salil Agarwal, Sr. AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 68

Hearing : 25.04.2023 Date of Pronouncement : 08.04.2023 ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER:- This appeal by the assessee is preferred against the order of the NFAC, Delhi dated 24.05.2021 pertaining to Assessment Year 2017-18. 2. The solitary grievance of the assessee is that the ld. CIT(A) erred in confirming

Harivadanbhai Maganlal Patel, Surat vs. Income Tax Officer, Ward 1(3)(7), Surat

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

ITA 30/SRT/2023[2013-14]Status: DisposedITAT Surat08 May 2023AY 2013-14

Bench: SHRI PAWAN SINGH (Judicial Member), DR. A. L. SAINI (Accountant Member)

For Appellant: Shri Sapnesh R Sheth, CAFor Respondent: Shri Vinod Kumar, Sr- DR
Section 143(3)Section 148Section 50C

IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JM & DR. A. L. SAINI, AM आयकर

Shree Raj Co-Operative Credit & Consumer Society Ltd., Surat vs. ACIT, Circle-3(3), Surat

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

ITA 187/SRT/2023[2017-18]Status: HeardITAT Surat08 May 2023AY 2017-18

Bench: Shri Pawan Singh(Physical Hearing) Shree Raj Co-Operative Credit & A.C.I.T., Consumers Society Ltd., Circle-3(3), Vs. 229, Nilkanth Plaza, Kiran Chowk, Surat. Puna Gam, Surat. Pan No. Aacts 7418 Q Appellant/ Assessee Respondent/ Revenue

Section 250(6)Section 254(1)Section 80Section 80P(2)(d)

PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by the assessee is directed against the order of learned National Faceless Appeal Centre, Delhi (NFAC)/Commissioner of Income Tax (Appeals) (in short, the ld. CIT(A)) dated 11/02/2023 for the Assessment Year (AY) 2017-18. The assessee has raised following grounds

Ganesh Ganpat Alim, Maharashtra vs. ITO Wasrd-3(3)(1), Surat

In the result, appeals filed by the assessee is allowed

ITA 41/SRT/2022[2012-13]Status: DisposedITAT Surat08 May 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.40/Srt/2022 "नधा"रण वष"/Assessment Year: (2012-13) (Physical Hearing) Ganesh Ganpat Alim, Vs. The Ito, B-205, Mahashakti Appartment, Ward -1(1)(1), Jai Shree Jahannath, Nr. Manvel Panda Surat. Road, Nr. Mahak City Virar East, Mumbai, Maharashtra – 401305. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ambpa5834F आयकर अपील सं./Ita No.41/Srt/2022 "नधा"रण वष"/Assessment Year: (2012-13) Ganesh Ganpat Alim, Vs. The Ito, B-205, Mahashakti Appartment, Ward -3(3)(1), Jai Shree Jahannath, Nr. Manvel Panda Surat. Road, Nr. Mahak City Virar East, Mumbai, Maharashtra – 401305. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ambpa5834F Appellant By Shri Sapnesh Sheth, Ca Respondent By Shri Ashok B. Koli, Cit(Dr) With Shri Vinod Kumar, Sr. Dr 22/03/2023 Date Of Hearing Date Of Pronouncement 08/05/2023 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Two Appeals Filed By The Assessee, Pertaining To Assessment Year (Ay) 2012-13, Are Directed Against The Orders Passed By The Learned Commissioner Of Income Tax (Appeals), [In Short “The Ld. Cit(A)”], Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer Under Section 144 R.W.S 147 & A Penalty Order Passed By The Assessing Officer Under Section 271(1)(C) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 144Section 271(1)Section 271(1)(c)

follows: “1. On the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income-tax (Appeals), NFAC has erred in passing ex- parte order without providing reasonable opportunity of hearing to assessee. 2. On the facts and circumstances of the case ... well as law on the subject, the learned Commissioner of income-Tax (Appeals), NFAC has erred confirming the action of assessing officer in imposing penalty of Rs.7,34,48,950/- u/s 271(1)(c) of the I.T. Act, 1961. 3. It is therefore prayed that penalty imposed by assessing officer

Ganesh Ganpat Alim, Maharashtra vs. Income Tax Officer, Ward-1(1)(1), Surat

In the result, appeals filed by the assessee is allowed

ITA 40/SRT/2022[2012-13]Status: DisposedITAT Surat08 May 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.40/Srt/2022 "नधा"रण वष"/Assessment Year: (2012-13) (Physical Hearing) Ganesh Ganpat Alim, Vs. The Ito, B-205, Mahashakti Appartment, Ward -1(1)(1), Jai Shree Jahannath, Nr. Manvel Panda Surat. Road, Nr. Mahak City Virar East, Mumbai, Maharashtra – 401305. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ambpa5834F आयकर अपील सं./Ita No.41/Srt/2022 "नधा"रण वष"/Assessment Year: (2012-13) Ganesh Ganpat Alim, Vs. The Ito, B-205, Mahashakti Appartment, Ward -3(3)(1), Jai Shree Jahannath, Nr. Manvel Panda Surat. Road, Nr. Mahak City Virar East, Mumbai, Maharashtra – 401305. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ambpa5834F Appellant By Shri Sapnesh Sheth, Ca Respondent By Shri Ashok B. Koli, Cit(Dr) With Shri Vinod Kumar, Sr. Dr 22/03/2023 Date Of Hearing Date Of Pronouncement 08/05/2023 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Two Appeals Filed By The Assessee, Pertaining To Assessment Year (Ay) 2012-13, Are Directed Against The Orders Passed By The Learned Commissioner Of Income Tax (Appeals), [In Short “The Ld. Cit(A)”], Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer Under Section 144 R.W.S 147 & A Penalty Order Passed By The Assessing Officer Under Section 271(1)(C) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

Section 144Section 271(1)Section 271(1)(c)

follows: “1. On the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income-tax (Appeals), NFAC has erred in passing ex- parte order without providing reasonable opportunity of hearing to assessee. 2. On the facts and circumstances of the case ... well as law on the subject, the learned Commissioner of income-Tax (Appeals), NFAC has erred confirming the action of assessing officer in imposing penalty of Rs.7,34,48,950/- u/s 271(1)(c) of the I.T. Act, 1961. 3. It is therefore prayed that penalty imposed by assessing officer

Golden Square Chs Ltd., Mumbai vs. ITO-22 (1)(5), Mumbai

In the result, the two appeals filed by the assesee are allowed

ITA 572/MUM/2023[2012-13]Status: DisposedITAT Mumbai05 May 2023AY 2012-13

Bench: Shir Pavan Kumar Gadaleita No. 572 & 573/Mum/2023 (A.Y: 2012-13 & 2013-14) Golden Square Chsltd., Vs. Ito – 22(1)(5),Roomno. Cst Road, Sunder Nagar 323,3Rdfloor,Piramal Kalina, Santicruz (E) Chamber,Lalbaug, Mumbai. 400098 Parel, Mumbai.400012 Pan/Gir No. : Aaaag2527M Appellant .. Respondent Appellant By : Shri Kunal Lunawat & Shri Rajendra Kumar Jain.Ar Respondent By : Shri Rajendra Chandekar.Dr Date Of Hearing 02.05.2023 Date Of Pronouncement 04.05.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: These Are The Two Appeals Filed The Assessee Against The Different Orders Of The National Faceless Appeal Centre (Nfac)/Cit(A), Delhi Passed U/S 250 Of The Act.

For Appellant: Shri Kunal Lunawat, &For Respondent: Shri Rajendra Chandekar.DR
Section 143(1)Section 154Section 154(7)Section 250Section 80PSection 80P(2)(d)

PAVAN KUMAR GADALE JM: These are the two appeals filed the assessee against the different orders of the National Faceless Appeal Centre (NFAC)/CIT(A), Delhi passed u/s 250 of the Act. 2. Since the issues in these appeals are common and identical, hence are clubbed, heard and a consolidated