“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

Mahesh Agarwal, Jaipur vs. ACIT - 6, Jaipur

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

ITA 4/JPR/2023[2014-15]Status: DisposedITAT Jaipur28 Mar 2023AY 2014-15

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

For Appellant: Shri Shyam Sunder Goyal, FCAFor Respondent: Smt. Runi Pal, Addl. CIT-DR

Section 10(38)Section 134ASection 143(3)Section 68Section 69C

assessee is directed against order of the ld. CIT(A) dated 15-12-2022, National Faceless Appeal Centre, Delhi [ hereinafter referred to as (NFAC) ] for the assessment year 2014-15 wherein the assessee has raised the following grounds of appeal. 1. Under the facts and circumstances of the case ... been filed online, which was beyond control to the assessee due to some technical reasons. Hence the appeal so dismissed by the Ld. NFAC is being totally contrary to the provisions of the law and facts on the record and hence kindly to be directed to treat the some

Income Tax Officer, Jaipur vs. Sonal Jain, Jaipur

In the result, the above appeals of the Revenue are dismissed

ITA 29/JPR/2023[2013-14]Status: DisposedITAT Jaipur28 Mar 2023AY 2013-14

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

For Appellant: Shri P.C. Parwal, CAFor Respondent: Shri Ajey Malik, CIT-DR fu/kZkfjrh dh vksj ls@

Section 138C

Revenue against four different orders of the ld. CIT(A) dated 24-11-2022,National Faceless Appeal Centre, Delhi [ hereinafter referred to as (NFAC) ] for the assessment years 2013-14 to 2016-17 wherein common grounds raised in the above appeals by the Revenue are as under. ‘’1. Whether

Om Prakash Kharol, Jaipur vs. ITO, WD4(3), Jaipur

In the result, all the appeals of the assessee are dismissed

ITA 442/JPR/2022[2009-10]Status: DisposedITAT Jaipur28 Mar 2023AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: NoneFor Respondent: Ms. Monisha Choudhary, Addl. CIT

Section 144Section 147Section 148

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Mk0 ,l- lhrky{eh

Om Prakash Kharol, Jaipur vs. ITO, WD4(3), Jaipur

In the result, all the appeals of the assessee are dismissed

ITA 441/JPR/2022[2009-10]Status: DisposedITAT Jaipur28 Mar 2023AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: NoneFor Respondent: Ms. Monisha Choudhary, Addl. CIT

Section 144Section 147Section 148

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Mk0 ,l- lhrky{eh

Om Prakash Kharol, Jaipur vs. ITO, WD4(3(, Jaipur

In the result, all the appeals of the assessee are dismissed

ITA 440/JPR/2022[2009-10]Status: DisposedITAT Jaipur28 Mar 2023AY 2009-10

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: NoneFor Respondent: Ms. Monisha Choudhary, Addl. CIT

Section 144Section 147Section 148

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Mk0 ,l- lhrky{eh

Sh. Laxman Singh Chahar, .R. Compounder Ki Gali, Devipura, Sikar vs. ITO, Ward-4, Sikar

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

ITA 434/JPR/2022[2010-11]Status: DisposedITAT Jaipur28 Mar 2023AY 2010-11

Bench: It, Hon’Ble Itat Is Prayed To Decide The Appeal On Merit Instead Of Setting Aside The Matter To Ld. Cit(A).

For Appellant: Shri P.C. Parwal , CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR

Section 250(6)

assessee is directed against order of the ld. CIT(A) dated 23-11-2022, 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. The ld. CIT(A), NFAC has erred on facts ... filed by the assessee and thereby not deciding the grounds of appeal on merit. 2. That once the ld. CIT(A), NFAC has not decided the grounds of appeal on merit even when the written submission alongwith the paper book was filed before it, Hon’ble ITAT is prayed

Sangeeta Bhatia, Jaipur vs. The DCIT, Circle-1 Jaipur

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

ITA 422/JPR/2022[2012-13`]Status: DisposedITAT Jaipur28 Mar 2023

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

For Appellant: Shri Manish Agarwal , CAFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR

Section 147Section 44A

assessee is directed against order of the ld. CIT(A) dated 07-10-2022, National Faceless Appeal Centre, Delhi [ hereinafter referred to as (NFAC) ] for the assessment year 2012-13 wherein the assessee has raised the following solitary ground of appeal. ‘’1. On the facts and in the circumstances

Dayaram Yadav, Jaipur vs. CIT(A), NFAC

In the result, appeal of the assessee is allowed

ITA 382/JPR/2022[2010-11]Status: DisposedITAT Jaipur28 Mar 2023AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri C. L. Yadav (C.A.) &For Respondent: Smt Monisha Choudhary (Addl. CIT) a

Section 253Section 253(5)Section 271(1)(b)

appeal is filed by assessee and is arising out of the order of the National Faceless Appeal Centre, Delhi dated 16/03/2022 [here in after (NFAC)/ ld. CIT(A) ] for assessment year 2010-11 which in turn arise from the three separate order of the penalty passed ... assessee filed an application for condonation of delay with following prayers: “On 16.03.2022, I received the order of Commissioner (Appeals) NFAC, Delhi, in my case for assessment year 2010-11. Being aggrieved by the said order I requested Messrs C.L. Yadav & Associates, Chartered Accountants, to prefer an appeal

Dinesh Kumar Sharma, Jaipur vs. ITO, Ward 4(3), Jaipur

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

ITA 36/JPR/2022[2012-13]Status: DisposedITAT Jaipur28 Mar 2023AY 2012-13

Bench: Hon’ble SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri H.M. Singhvi, CAFor Respondent: Smt. Monisha Choudhary, Addl. CIT-DR

Section 148Section 154Section 194J

assessee is directed against order of the ld. CIT(A) dated 10-11-2021, National Faceless Appeal Centre, Delhi [ hereinafter referred to as (NFAC) ] for the assessment year 2012-13 wherein the assessee has raised the following ground of appeal. ‘’1. That the ld. CIT(A) passed the ex-parte

Bimal Roy Soni, J L N Marg vs. DCIT, Circle - 1, Jaipur, Statue Circle

In the result, appeals of the assessee is partly allowed

ITA 240/JPR/2022[2014-15]Status: DisposedITAT Jaipur28 Mar 2023AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. Nos. 239 & 240/JP/2022 fu/kZkj.k o"kZ@Assessment Years : 2013-14 & 2014-15 Bimal Roy Soni 11, Chetak Marg, JLN Marg Jaipur cuke Vs. DCIT, Circle-01, Jaipur NCR, Building LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AFPPS 1588 H vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@ Assessee by : Shri Akhilesh Kumar Jain (C.A.) jktLo dh vksj ls@ Revenue by : Smt Runi Pal (Addl. CIT) a lquokb

For Appellant: Shri Akhilesh Kumar Jain (C.A.)For Respondent: Smt Runi Pal (Addl. CIT) a

Section 143(3)Section 14ASection 154Section 254

appeals filed by the assessee is arising out of the order of the National Faceless Appeal Centre, Delhi dated 04/04/2022 [here in after (NFAC)] for assessment years 2013-14 & 2014-15 which in turn arise from the order dated 25.10.2018 passed under section 154 of the Income ... unable to issue directions to restrict the disallowance u/s 14A to the extent of exempted income.” 6. As the ld. CIT(A) / NFAC has not given any finding on the merits of the case the ld. AR of the assessee contended that the direction of the tribunal is not followed

Bimal Roy Soni, J L N Marg vs. DCIT, Circle-1, Jaipur, N.C.R. Building

In the result, appeals of the assessee is partly allowed

ITA 239/JPR/2022[2013-14]Status: DisposedITAT Jaipur28 Mar 2023AY 2013-14

For Appellant: Shri Akhilesh Kumar Jain (C.A.)For Respondent: Smt Runi Pal (Addl. CIT) a

Section 143(3)Section 14ASection 154Section 254

Veena Devi Jagatramka, Sambalpur vs. ITO Ward-1(1), Sambalpur

In the result, appeal of the assessee stands allowed

ITA 199/CTK/2022[2017-18]Status: HeardITAT Cuttack27 Mar 2023AY 2017-18

Bench: Before S/Shri George Mathan, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2017-18 Veena Devi Jagatramka, Veena Devi Jagatramka, Vs. Ito, Ward 2(1), Ito, Ward 2(1), Bhatradhanupali, Bhatradhanupali, Sambalpur Sambalpur Sambalpur. Pan/Gir No. Pan/Gir No.Aaupj 6186 A (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri Rahul Agarwal, Ar Rahul Agarwal, Ar Revenue By : Shri S.C.Mohanty, Sr Dr S.C.Mohanty, Sr Dr Date Of Hearing : 27 /0 03/2023 Date Of Pronouncement : 27 /0 /03/2023 O R D E R Per Bench This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld This Is An Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), , Nfac, Nfac, Delhi, Delhi, Dated 24.11.2022 24.11.2022 In Appeal No. Itba/Nfac/S/250/2022 Itba/Nfac/S/250/2022-23 /1047617611(1) For The Assessment Year The Assessment Year 2017- 18. 2. Shri Rahul Agarwal, Ld Ar Appeared For The Assessed & Shri Shri Rahul Agarwal, Ld Ar Appeared For The Assessed & Shri Shri Rahul Agarwal, Ld Ar Appeared For The Assessed & Shri S.C.Mohanty, Ld Sr Dr Appeared For The Revenue. S.C.Mohanty, Ld Sr Dr Appeared For The Revenue.

For Appellant: Shri Rahul Agarwal, ARFor Respondent: Shri S.C.Mohanty, Sr DR

assessee against the order of the ld This is an appeal filed by the assessee against the order of the ld CIT(A), , NFAC, NFAC, Delhi, Delhi, dated 24.11.2022 24.11.2022 in Appeal No. ITBA/NFAC/S/250/2022 ITBA/NFAC/S/250/2022-23 /1047617611(1) for the assessment year the assessment year 2017- 18. 2. Shri Rahul Agarwal ... Order forwarded to : 1. The Appellant : Veena Devi Jagatramka, Bhatradhanupali, Sambalpur. 2. The Respondent: ITO, Ward 2(1), Sambalpur 3. The CIT(A)-, NFAC, Delh 4. Pr.CIT-, Sambalpur 5. DR, ITAT, Cuttack 6. Guard file. //// By order Sr.Pvt.secretary ITAT, Cuttack

Jmk Enterprises Pvt. Ltd., Delhi vs. DCIT Circle 13(2), Delhi

In the result, appeal of assessee is allowed

ITA 469/DEL/2022[2017-18]Status: DisposedITAT Delhi27 Mar 2023AY 2017-18

Bench: Sh. Anil Chaturvedi & Sh. Narender Kumar Choudhryjmk Enterprises Pvt. Ltd. Vs. Dcit C-3, Ground Floor, Circle – 13(2) Backside Amar Colony Delhi Market, Lajpat Nagar Delhi-110 024 Pan No. Aabcj 8796 Q (Appellant) (Respondent) Assessee By Shri Saurav Rohtagi, C.A. Revenue By Shri Anuj Garg, Sr. D.R. Date Of Hearing: 01.03.2023 Date Of Pronouncement: 27.03.2023 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.05.2021 Passed By The Commissioner Of Income Tax (Appeals)-Nfac, Delhi Relating To Assessment Year 2017-18. 2. Brief Facts Of The Case As Culled Out From The Material On Record Are As Under :- Jmk Enterprises Pvt. Ltd. Vs Dcit 2 3. Assessee Is A Company Stated To Be Engaged In The Business Of Jewellery Dealership & Retailing The Products. Assessee Electronically Filed Its Return Of Income For A.Y. 2017-18 On 21.06.2017 Declaring Total Income Of Rs.95,27,960/- Which Was Later Revised On 22.08.2017 With No Change In The Total Taxable Income. The Case Of The Assessee Was Selected For Scrutiny & Thereafter, Assessment Was Framed U/S 143(3) Vide Order Dated 21.11.2019 & The Total Income Was Determined At Rs.1,05,49,060/-.

Section 143(3)Section 192Section 192BSection 40

ANIL CHATURVEDI, AM: This appeal filed by the assessee is directed against the order dated 19.05.2021 passed by the Commissioner of Income Tax (Appeals)-NFAC, Delhi relating to Assessment Year 2017-18. 2. Brief facts of the case as culled out from the material on record are as under

Fine Gujranwala Jewellers, New Delhi vs. ITO, Ward-51(3), New Delhi

In the result the appeal of the assessee is allowed

ITA 1540/DEL/2022[2017-18]Status: DisposedITAT Delhi27 Mar 2023AY 2017-18

Bench: Shri Anil Chaturvedi & Shri Yogesh Kumar U.S.

For Appellant: Shri K. Sampath, Advocate

Section 285BSection 68

order dated 21.06.2022 of the ld. Commissioner of Income Tax (Appeals) (hereinafter 2 Fine Gujranwala Jewellers, referred to CIT (Appeals)/National Faceless Appeal Centre (NFAC) Delhi, for assessment year 2017-18. 2. The assessee has raised the following substantive ground of appeal :- “On the facts and in the circumstances ... case and in law the NFAC, CIT(A) Delhi (Qua) erred in confirming the additions of Rs.1,37,95,040/- made by the Assessing Officer on account of cash deposited in bank by wrongly invoking section 68 r.w.s. 115BBE of the Act. Such actions being arbitrary, fallacious, unwarranted and illegal

Vivek Kumar Batra, Jagdalpur vs. Income Tax Officer Ward- Jagdalpur, Bastar

In the result, appeal of the assessee is allowed for statistical purposes in terms of my aforesaid observations

ITA 232/RPR/2022[2019-20]Status: DisposedITAT Raipur27 Mar 2023AY 2019-20

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No. 232/Rpr/2022 "नधा"रण वष" / Assessment Year : 2019-20 Vivek Kumar Batra 1, Geedam Road, Jagdalpur, Chhatisgarh-494 001 Pan : Adfpb7478M .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-Jagdalpur. ……""यथ" / Respondent

For Appellant: Shri N.C Gupta, AdvocateFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 139(1)Section 143(1)Section 143(1)(a)Section 43BSection 44A

present appeal filed by the assessee is directed against the order passed by the Commissioner of Income-Tax (Appeals), National Faceless Appeal Center (NFAC), Delhi, dated 25.10.2022, which in turn arises from the intimation passed by the Centralized Processing Center (CPC)/A.O under Sec.143(1) of the Income ... impugned order on the following grounds of appeal: “1. That under the facts and the law, the learned Commissioner of Income Tax (Appeals), NFAC, Delhi erred in making disallowance by way of adjustment of Rs.80,289/- u/s 43B made by AO CPC in intimation u/s 143(1) for non- payment

Shri Narbarda Parsad Gupta, Surajpur vs. Income Tax Officer, Ward - 2, Sarguja

In the result, appeal of the assessee is partly allowed for statistical purposes in terms of my aforesaid observations

ITA 205/RPR/2022[2015-16]Status: DisposedITAT Raipur27 Mar 2023AY 2015-16

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No.205/Rpr/2022 "नधा"रण वष" / Assessment Year : 2015-16 Narbarda Prasad Gupta, S/O. Hari Prasad Gupta, Vill. Darripara, P.O-Bhaiyathan, Surajpur-497 231 (C.G.) Pan : Aujpg0494R .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-2, Ambikapur, Dist. Sarguja. ……""यथ" / Respondent

For Appellant: Shri S.R. Rao, AdvocateFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 144Section 147Section 148Section 44A

present appeal filed by the assessee is directed against the order passed by the Commissioner of Income-Tax (Appeals), National Faceless Appeal Center (NFAC), Delhi, dated 30.06.2022, which in turn arises from the order passed by the A.O under Sec. 144/147 of the Income-tax Act, 1961 (in short

Ganeshan Purushothaman Achari, Bhilai, Durg vs. Income Tax Officer-1(4), Bhilai, Durg

In the result, appeal of the assessee in ITA No

ITA 148/RPR/2022[2019-20]Status: DisposedITAT Raipur27 Mar 2023AY 2019-20

Bench: Shri Ravish Soodआयकर अपील सं./ Ita Nos. 146 To 148/Rpr/2022 "नधा"रण वष" / Assessment Year : 2017-18 To 2019-20 Ganeshan Puroshothaman Achari 116, Friends Arcade, Shastri Nagar, G.E. Road, Supela, Bhilai (C.G.) Pan : Achpa6510E .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax Cpc, Bengaluru. ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 143(1)Section 36Section 43B

captioned appeals filed by the assessee are directed against the respective orders passed by the Commissioner of Income-Tax (Appeals), National Faceless Appeal Center (NFAC), Delhi, dated 03.06.2022 and 02.06.2022, which in turn arises from the intimations passed by the Centralized Processing Center (CPC)/A.O under

Ganeshan Purushothaman Achari, Bhilai, Durg vs. Income Tax Officer-1(4), Bhilai, Durg

In the result, appeal of the assessee in ITA No

ITA 147/RPR/2022[2018-19]Status: DisposedITAT Raipur27 Mar 2023AY 2018-19

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 143(1)Section 36Section 43B

Ganeshan Purushothaman Achari, Bhilai, Durg vs. Income Tax Officer-1(4), Bhilai, Durg

In the result, appeal of the assessee in ITA No

ITA 146/RPR/2022[2017-18]Status: DisposedITAT Raipur27 Mar 2023AY 2017-18

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Piyush Tripathi, Sr. DR

Section 143(1)Section 36Section 43B

Reetu Devi Nanecha, Bhilwara vs. ITO TDS, Bhilwara

In the result, the appeal of the assessee is allowed

ITA 118/JODH/2021[2015-16]Status: DisposedITAT Jodhpur24 Mar 2023AY 2015-16

Bench: Shri Kul Bharat & Shri Manish Borad118/Jodh/2021 (Assessment Year- 2015-16) Vs Reetu Devi Nanecha, The Ito 3A 38, R.C, Vyas Colony, Tds, Bhilwara, Rajasthan Bhilwara (Appellant) (Respondent) Pan No. Accpn2756J

Section 194Section 201Section 201(1)

This is an appeal filed by the assessee against the order of the ld. CIT(A), National Faceless Appeal Centre, Delhi (for short ‘’NFAC’’), 2 SMT. RITU DEVI NANECHA VS ITO, TDS, BHILWARA Delhi dated 20-10-2021 for the assessment year 2015-16 raising therein following grounds of appeal