“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

Deputy Commissioner of Income Tax, Cir-2(1)(1), Baroda vs. The Bharuch Dis Cent Co-Op Bank Ltd., Bharuch

ITA 296/SRT/2022[2013-14]Status: DisposedITAT Surat09 Jan 2023AY 2013-14

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 254(1)Section 36(1)(viia)

PAWAN SINGH, JUDICIAL MEMBER: 1. These three appeals by the Revenue are directed against the separate orders of National Faceless Appeal Centre, Delhi (NFAC)/learned Commissioner of Income Tax (Appeals) (in short, the ld. CIT(A) all dated 16/08/2022 for the Assessment years

Abhishek Navnitkumar Doshi, Surat vs. Income Tax Officer, WD. 2(3)(7), Surat

In the result the ground No

ITA 21/SRT/2022[2012-13]Status: DisposedITAT Surat09 Jan 2023AY 2012-13

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No. 21/Srt/2022 Assessment Year: (2012-13) (Physical Court Hearing) Abhishek Navnitkumar Doshi, Vs. The Ito, Ward-2(3)(7), 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) आयकर अपील सं./Ita No.38/Srt/2022 Assessment Year: (2012-13) The Ito, Ward-2(3)(6), Vs. Abhishek Navnitkumar Doshi, 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) Assessee By Shri Sapnesh Sheth, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 28/12/2022 09/01/2023 Date Of Pronouncement

Section 132Section 143(3)Section 148

common order passed by the Learned Commissioner of Income Tax (Appeals), [in short “the ld. CIT(A)”], National Faceless Appeal Centre (in short ‘the NFAC’), Delhi, which in turn arise out of an assessment order passed by the Assessing Officer under section 143(3) r.w.s 147 of the Income

Income Tax Officer, Ward-1, Srikakulam vs. Primary Agricultural Co Operative Credit Society, Haripuram

In the result, the appeal of the revenue is dismissed

ITA 209/VIZ/2022[2018-19]Status: DisposedITAT Visakhapatnam06 Jan 2023AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.209/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2018-19) Income Tax Officer Vs. Primary Agricultural Co- Ward-1 Operative Credit Society Srikakulam 1-116, Haripuram Mandasa, Srikakulam [Pan : Aacap0308D] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Shri Sankar Pandi, Dr सुनवधई की तधरीख / Date Of Hearing : 04.01.2023 घोर्णध की तधरीख/Date Of Pronouncement : 06.01.2023

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri Sankar Pandi, DR

Reddy, Judicial Member : This appeal is filed by the revenue against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi in DIN & Order No.ITBA/NFAC/S/250/2022- 23/1045776054(1) dated 21.09.2022 for the Assessment Year (A.Y.) 2018-19. 2. When this appeal is taken up for hearing ... Srikakulam 3. The Principal Commissioner of Income Tax (Central), Visakhapatnam 4. आयकर आयुक्त (अपील)/ The Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi 5. नवभधगीय प्रनतनननध, आयकर अपीलीय अनधकरण, नवशधखधपटणम DR,ITAT, / Visakhapatnam 6.गधर्ा फ़धईल / Guard file आदेशधनुसधर / BY ORDER Sr. Private Secretary ITAT, Visakhapatnam

Manuchukonda Sri Ram, Vizianagaram vs. Income Tax Office, Ward-2, Vizianagaram

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

ITA 178/VIZ/2022[2017-18]Status: DisposedITAT Visakhapatnam06 Jan 2023AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.178/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2017-18) Manchokonda Sri Ram Vs. Income Tax Officer D.No.7-1-36, Ward-1 Manchukonda Vari Veedhi Vizianagaram Vizianagaram [Pan : Acnpr3037M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri G.V.N.Hari, Ar प्रत्यधथी की ओर से / Respondent By : Shri Sankar Pandi, Dr सुनवधई की तधरीख / Date Of Hearing : 04.01.2023 घोर्णध की तधरीख/Date Of Pronouncement : 06 .01.2023

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri Sankar Pandi, DR

Section 115BSection 133(6)Section 139(4)Section 142Section 142(1)Section 69A

Reddy, Judicial Member : This appeal is filed by the assessee against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi in DIN & Order No.ITBA/NFAC/S/250/2022- 23/1044013388(1) dated 22.07..2022 for the Assessment Year (A.Y.) 2017-18. 2. Brief facts of the case are that ... रधजस्व/The Revenue –Income Tax Officer, Ward-1, Vizianagaram 3. आयकर आयुक्त (अपील)/ The Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi 4. नवभधगीय प्रनतनननध, आयकर अपीलीय अनधकरण, नवशधखधपटणम / DR,ITAT, Visakhapatnam . गधर्ा फ़धईल / Guard file 5 आदेशधनुसधर / BY ORDER Sr. Private Secretary ITAT, Visakhapatnam

Shri Jorubha Jilubha Jadeja, Village Zankhar Post Vidinar Taluka Lalpur, Dist Jamnagar vs. The DCIT, Circle-2(2), Jamnagar

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

ITA 3/RJT/2022[2017-18]Status: DisposedITAT Rajkot06 Jan 2023AY 2017-18

Bench: Ms. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 143(3)Section 68Section 69C

against the Appellate order dated 06.12.2021 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as “NFAC”), arising out the Assessment order passed under section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating ... thereon. 3. Aggrieved against the assessment order, the assessee filed an apepal before the Commissioner of Income Tax (Appeals). The appeal was migrated to NFAC and the assessee filed his submission before the NFAC Centre. After considering the submissions, the Ld. CIT(A)-NFAC partly allowed assessee’s appeal

Simple Singh, Meerut vs. ITO Ward-1(2)(5), Meerut

In the result, the appeal of the assessee is allowed

ITA 1367/DEL/2022[2011-12]Status: DisposedITAT Delhi05 Jan 2023AY 2011-12

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia[Assessment Year : 2011-12] Simple Singh, Vs Ito, Kartar Singh & Co., 86, Bank Street, Ward-1(2)(5), Meerut Cantt., Meerut, Meerut. Uttar Rpadesh-250001. Pan-Awmps7877F Appellant Respondent Appellant By Shri R.P.Narang, Adv. Respondent By Shri Abhishek Kumar, Sr.Dr Date Of Hearing 21.12.2022 Date Of Pronouncement 05.01.2023

Section 142(1)Section 144Section 147Section 148Section 271(1)(b)

appeal filed by the assessee for the assessment year 2011-12 is directed against the order of Ld. CIT(A), National Faceless Appeal Centre (“NFAC”), Delhi dated 29.04.2022. 2. The assessee has raised following grounds of appeal:- 1. “That the Ld. CIT(A), NFAC, New Delhi is erred ... been served or gone astray is most arbitrary and uncalled for in/ any case is highly excessive. 2. That the ld. CIT(A), NFAC, New Delhi was not justified while confirming the penalty imposed by Assessing Officer without affording 1 | P a g e an opportunity to rebut the claim

Aishwarya Africawala, Mumbai vs. Income Tax Officer, Ward2(2)(1), Surat

In the result, the grounds of appeal raised by assessee are allowed for statistical purpose

ITA 338/SRT/2022[2017-18]Status: DisposedITAT Surat05 Jan 2023AY 2017-18

Bench: Shri Pawan Singh(Virtual Hearing) Aishwarya Africawala, I.T.O.,Ward 2(2)1, B-305, G N Tower, Near Reliance Room No. 629, Vs. Degital, S.V. Road, Andheri (W), Aayakar Bhawan, Mumbai- 400058 Near Majura Gate, Ph. 9769127825 Opposite New Civil Hospital Email:Aishwaryaafricawalvlogs@Gmail.Com Surat Pan No. Bopqa 1425 J Appellant/ Assessee Respondent/ Revenue

Section 115BSection 144Section 254(1)

PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by assessee is directed against the order of National Faceless Appeal Centre, Delhi (in short, the NFAC)/learned Commissioner of Income Tax (Appeals) (in short, the ld. CIT(A) dated 29/09/2022 for the Assessment years (AY) 2017-18. 2. At the outset ... made various addition of aggregating of Rs. 20.65 lakhs by taking view that the assessee filed to provide complete details. The ld CIT(A)/ NFAC dismissed the appeal of assessee by holding that the notice to the assessee was served on the assessee but no response was received. No satisfaction

Raj Singh, Delhi vs. ITO Ward-62(4), Delhi

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

ITA 1135/DEL/2022[2017-18]Status: DisposedITAT Delhi04 Jan 2023AY 2017-18

Bench: Shri Anil Chaturvedi & Shri Narender Kumar Choudhry

For Appellant: Shri Maynk Kouts, AdvocateFor Respondent: Shri A K Arora, Sr DR

Section 115BSection 139Section 142(1)Section 144Section 250Section 69

failed to appreciate the submissions made and arbitrary making the addition of Rs84,22,326/- on account of duty-draw back. 6. That the NFAC also failed to grant opportunity to the Assessee and thereafter arbitrary dismissing the appeal. 4 ITA.No. 1135/Del./2022 7. The order

Jay Narayan Periwal, Surat vs. Income Tax Officer, Ward - 2(3)(1), Surat

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

ITA 326/SRT/2022[2020-21]Status: DisposedITAT Surat04 Jan 2023AY 2020-21

Bench: Shri Pawan Singh(Physical Hearing) Jay Narayan Periwal, I.T.O. 144-149, Behind Bharat Petrol Pump, Ward-2(3)(1), Vs. Near Komal Circle, Bamroli Road, Surat. Surat. Pan No. Acjpp 7250 N Appellant/ Assessee Respondent/ Revenue

Section 254(1)Section 43B

Geeta Devi Saini, Jaipur vs. DCIT/ ITO, Jaipur

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

ITA 285/JPR/2022[2011-2012]Status: DisposedITAT Jaipur04 Jan 2023AY 2011-2012

Bench: The Ld. Pr. Cit, Jaipur For Obtaining Approval Inasmuch Assessee Has Purchased Geeta Devi Saini Vs Dcit,Circle-4, Jaipur

For Appellant: Shri Shyam Sunder Jangid, AdvFor Respondent: Smt. Monisha Choudhary, JCIT

Section 148Section 68

assessee is directed against order of the ld. CIT(A) dated 24-05-2022, National Faceless Appeal Centre, Delhi [ hereinafter referred to as (NFAC) ] for the assessment year 2011-12 raising therein following grounds of appeal. ‘’1. On the facts and circumstances of the case

D K Mehta (HUF), Umbergaon vs. The Income Tax Officer, Ward 2, Vapi

In the result, the grounds of appeal raised by assessee are allowed for statistical purpose

ITA 310/SRT/2022[2016-17]Status: DisposedITAT Surat03 Jan 2023AY 2016-17

Bench: Shri Pawan Singh(Virtual Hearing) Kaushikbhai Jitendrabhai Patel, I.T.O.,Ward 1(4), Amin Falia, Zadeshwar, Bharuch. Vs. Bharuch-392011. Pan No. Axlpp 0562 G Appellant/ Assessee Respondent/ Revenue D.K. Mehta (Huf), I.T.O.,Ward-2, 11, At Post Solsumba, Gangadevi Vapi. Vs. Road, Umbergaon Road, Umbergaon-396165, Gujarat. Pan No. Aagdh 4494 R Appellant/ Assessee Respondent/ Revenue

Section 143(3)Section 250Section 250(6)Section 254(1)Section 68

MEMBER: 1. These two appeals by two different assessees are directed against the separate orders of National Faceless Appeal Centre, Delhi (in short, the NFAC)/learned Commissioner of Income Tax (Appeals) (in short, the ld. CIT(A) dated 29/06/2022 and 12/09/2022 for the Assessment years ... treated as a “lead case”. In this appeal, the assessee has raised following grounds of appeal: “1. The ld. CIT(A)-NFAC erred on facts and in law in deciding appeal ex parte without adjudicating the appeal on the grounds raised in For, No. 35 in terms of Section

Pravinaben Pravinbhai Patel, Surat vs. Add. Commissioner of Income Tax, Range 1(3), Surat

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

ITA 302/SRT/2022[2015-16]Status: HeardITAT Surat03 Jan 2023AY 2015-16

Bench: Shri Pawan Singh(Virtual Hearing) Shri Pravinbhai Keshavbhai Patel, Addl.C.I.T.,Range-1(3), A/2, Golden Park Society, Surat Vs. Opp. Prime Arcade, Aanand Mahal Road, Adajan, Surat. Pan No. Adgpp 4549 L Appellant/ Assessee Respondent/ Revenue Smt. Pravinaben Pravinbhai Patel, Addl.C.I.T.,Range-1(3), A/2, Golden Park Society, Surat Vs. Opp. Prime Arcade, Aanand Mahal Road, Adajan, Surat. Pan No. Cdopp 3300 D Appellant/ Assessee Respondent/ Revenue

Section 143(3)Section 254(1)Section 269SSection 271(1)(c)Section 271DSection 69Section 69C

JUDICIAL MEMBER: 1. These two appeals by two assessees are directed against the separate orders of National Faceless Appeal Centre, Delhi (in short, the NFAC)/learned Commissioner of Income Tax (Appeals) (in short, the ld. CIT(A) dated 10/12/2021 and 15/09/2022 which in turn arises from the order of penalty ... appeal: “1. On the facts and circumstances of the case as well as law on subject the learned CIT(A) National Faceless Appeal Centre (NFAC) Delhi erred in dismissing the appeal without properly considering the facts of the case. And case laws on which your appellant relied.” 2. Brief facts

Pravinbhai Keshavbhai Patel, Surat vs. Addl. Commissioner of Income Tax, Range 1(3), Surat

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

ITA 301/SRT/2022[2015-16]Status: HeardITAT Surat03 Jan 2023AY 2015-16

Section 143(3)Section 254(1)Section 269SSection 271(1)(c)Section 271DSection 69Section 69C

Kaushikbhai Jitendrabhai Patel, Bharuch vs. Income Tax Officer, Ward 1(4), Bharuch

In the result, the grounds of appeal raised by assessee are allowed for statistical purpose

ITA 260/SRT/2022[2015-16]Status: DisposedITAT Surat03 Jan 2023AY 2015-16

Section 143(3)Section 250Section 250(6)Section 254(1)Section 68

Assitant Commissioner of Income Tax, Cir.1(3), Surat vs. Sarjan Co-Op.Housing Society Ltd., Surat

In the result, this appeal of revenue is dismissed

ITA 189/SRT/2022[2014-15]Status: DisposedITAT Surat03 Jan 2023AY 2014-15

Bench: Shri Pawan Singh(Virtual Hearing) A.C.I.T., Sarjan Cooperative Society Ltd., Circle-1(3), Sarjan Bhavan, Athwalines, Vs. Surat. Surat-395007 Pan No. Aadas 2575 C Appellant/ Assessee Respondent/ Revenue

Section 2Section 254(1)Section 263Section 28Section 56Section 80PSection 80P(2)(d)

PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by the revenue is directed against the order of National Faceless Appeal Centre, Delhi (in short, the NFAC)/learned Commissioner of Income Tax (Appeals) (in short, the ld. CIT(A) dated 11/05/2022 for the Assessment year (AY) 2014-15. The revenue has raised

Share India Fincap Private Ltd., New Delhi vs. DCIT Circle-22(2), New Delhi

Appeal of the assessee is allowed for statistical purposes

ITA 1571/DEL/2022[2016-17]Status: DisposedITAT Delhi02 Jan 2023AY 2016-17

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharat[Assessment Year: 2016-17

Section 143(1)Section 143(3)Section 271(1)(c)Section 5(2)Section 6

BHARAT, JM: This appeal, by the assessee, is directed against the order of the learned Commissioner of Income-tax (Appeals), National Faceless Assessment Centre (NFAC), Delhi, dated 11.05.2022, pertaining to the assessment year 2016-17. The assessee has raised following grounds of appeal: “1. 1. That the appellant prays that

Anupama Chathankandath, Palakkad vs. The ACIT Circle-1, Palakkad

In the result, appeals are allowed

ITA 27/COCH/2022[2013-14]Status: DisposedITAT Cochin02 Jan 2023AY 2013-14

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri. Padmanathan, CAFor Respondent: Smt. J M Jamuna Devi, SR AR

Padmavathy S, Accountant Member These two appeals are against the order of CIT(A), National Faceless Appeal Centre (NFAC), dated 18.11.2021, for Assessment Year 2012-13 and 2013-14. These two appeals are heard together and disposed of by this common order for the sake of convenience and brevity

Anupamachathankandath, Palakkad vs. The ACIT Circle-1, Palakkad

In the result, appeals are allowed

ITA 26/COCH/2022[2012-13]Status: DisposedITAT Cochin02 Jan 2023AY 2012-13

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

For Appellant: Shri. Padmanathan, CAFor Respondent: Smt. J M Jamuna Devi, SR AR

Madresa Himayatul Islam Bachchon Ka Ghar, Bardoli vs. Income Tax Officer, Exemption Ward, Surat

In the result, the grounds of appeal raised by assessee are allowed for statistical purpose

ITA 279/SRT/2022[2017-18]Status: HeardITAT Surat02 Jan 2023AY 2017-18

Bench: Shri Pawan Singh(Physical Hearing) Madresa Himayatul Islam Bachchon Ka I.T.O. Ghar, Exemption Ward, Vs. Ground Floor Bachchon Ka Ghar, Surat. Kadod, Bardoli-394335. Pan No. Aadtm 1802 F Appellant/ Assessee Respondent/ Revenue

Section 115BSection 12ASection 133(6)Section 144Section 249Section 249(4)Section 254(1)Section 69A

PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by the assessee is directed against the order of National Faceless Appeal Centre, Delhi (in short, the NFAC)/learned Commissioner of Income Tax (Appeals) (in short, the ld. CIT(A) dated 26/05/2022 for the Assessment year (AY) 2017-18. The assessee has raised ... under Section 144. 3. Aggrieved by the addition, the assessee filed appeal before the ld. CIT(A). The appeal of assessee was migrated to NFAC. The NFAC/ ld. CIT(A) dismissed the appeal of assessee by holding that the assessee has not paid due tax as per Section

Chandrakant Bhagwanji Popat, Surat vs. Dy. Commissioner of Income Tax, Cir. 1(3), Surat

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

ITA 265/SRT/2022[2015-16]Status: HeardITAT Surat02 Jan 2023AY 2015-16

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Hearing) Chandrakant Bhagwanji Popat, D.C.I.T., 54, Dev Deep Society, Circle-1(3), Vs. Ichchhanath Road, Surat. Surat. Pan No. Abnpp 1088 R Appellant/ Assessee Respondent/ Revenue

Section 112Section 250(6)Section 254(1)Section 54F

PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by the assessee is directed against the order of National Faceless Appeal Centre, Delhi (NFAC)/learned Commissioner of Income Tax (Appeals), (in short, the ld. CIT(A)) dated 22/07/2022 for the Assessment year (AY) 2015-16 wherein the assessee has raised following grounds ... appeal: 1. On the facts and circumstances of the case, as well as law on the subject, the Learned Commissioner of Income Tax (Appeals) - NFAC, Delhi has erred in confirming the action of Deputy Commissioner of Income Tax disallowing claimed of deduction u/s 54F of the Act in spite