“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

Damyanti Shah, King Circle vs. Income Tax Officer 20(1)(1) Mumbai, Lalbaug

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

ITA 5879/MUM/2025[2013-14]Status: DisposedITAT Mumbai17 Dec 2025AY 2013-14

Bench: Us, The Learned Counsel For The Assessee Has Submitted That A Detailed & Cogent Explanation Justifying The Delay In Filing Of The First Appeal Was Duly Placed On Record Before The Ld. Cit(A). It Has Been Contended That The Delay Was Neither Deliberate Nor Contumacious, But Was Occasioned Due To Circumstances Beyond The Control Of The Assessee.

Section 144Section 147

AMIT SHUKLA (J.M): The present appeal has been preferred by the assessee against the order dated 22.09.2025 passed by the National Faceless Appeal Centre (NFAC), Delhi, whereby the appeal of the assessee was dismissed, primarily on the ground of delay, in respect of an assessment framed under section 147 read

M/S. Devisha Infrastructure Pvt Ltd, Mumbai vs. ITO Ward 6(2)(2), Mumbai

In the result, appeal of the assessee ITA No

ITA 5782/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Dec 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Nishit GandhiFor Respondent: Shri Umashankar Prasad (SR DR)

Section 143(3)Section 147Section 148Section 148ASection 151Section 250Section 282ASection 41(1)

Anikesh Banerjee (JM): These two appeals of the assessee werefiled against the order of the National Faceless Appeal Centre(NFAC), Delhi [hereinafter, ‘Ld.CIT(A)] passed under section 250 of the Income-tax Act, 1961 (in short, ‘the Act’) for the Assessment Years 2017-18 & 2019-20, date of order 21/08/2025

M/S. Devisha Infrastructure Pvt Ltd, Mumbai vs. ITO Ward 6(2)(2), Mumbai

In the result, appeal of the assessee ITA No

ITA 5781/MUM/2025[2019-20]Status: DisposedITAT Mumbai17 Dec 2025AY 2019-20

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Nishit GandhiFor Respondent: Shri Umashankar Prasad (SR DR)

Section 143(3)Section 147Section 148Section 148ASection 151Section 250Section 282ASection 41(1)

The Institute of Marine Engineers India, Mumbai vs. ITO Ward 2(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5666/MUM/2025[2009-10]Status: DisposedITAT Mumbai17 Dec 2025AY 2009-10

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Karthik Natarajan, CAFor Respondent: Shri Virabhadra Mahajan, SR DR

Section 11Section 143(3)Section 250Section 254

Anikesh Banerjee (JM): The instant appeal of the assessee filed against the order of the National Faceless Appeal Centre(NFAC), Delhi [hereinafter, ‘Ld.CIT(A)] passed under section 250 of the Income-tax Act, 1961 (in short, ‘the Act’) for the Assessment Year 2009-10, date of order 17/07/2025. The impugned

Vama International, Mumbai vs. ACIT 22(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5456/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Dec 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Dharan Gandhi, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)

Section 143(1)Section 147Section 148

IN THE INCOME-TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT

Shivi Mukesh Kumar, Mumbai vs. ACIT, Circle 22(1), Mumbai

In the result, the appeal is partly allowed as indicated above

ITA 5293/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Dec 2025AY 2016-17

Bench: Shri Saktijit Dey & Shri Jagadishshivi Mukesh Kumar Acit, Circle 22(1) D-1402, Hubtown Seasons, Mumbai Next To Fine Arts Society, Vs. Ramakrishna Chemburkar Marg, Chembur, Mumbai-400 071 Pan/Gir No. Aqapk 9881 H (Appellant) : (Respondent) Appellant By : Shri Dharan V. Gandhi – Advocate & Ms. Vinita A. Nara – Advocate Respondent By : Shri Arun Kanti Datta – Cit Dr Date Of Hearing : 11.12.2025 Date Of Pronouncement : 17.12.2025 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against The Order Dated 01.07.2025, Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Assessment Year (A.Y.) 2016-17. 2. Though, The Assessee Has Raised Multiple Grounds, However, At The Time Of Hearing, Ld. Counsel Appearing For The Assessee Specifically Drew Our Attention To Ground No. 6, Which Reads As Under: 6. The Sanction U/S. 151 Is Bad In Law & As A Result, The Reassessment Proceeding Is Bad In Law. 3. Referring To This Ground, Ld. Counsel Submitted, At The Very Outset, This Issue May Be Considered And, If Warranted The Other Issues Can Be Taken Up Thereafter. As Could Be Seen

For Appellant: Shri Dharan V. Gandhi – Advocate &For Respondent: Shri Arun Kanti Datta – CIT DR

Section 133ASection 143(3)Section 147Section 148Section 151Section 35(1)(ii)

Saktijit Dey, Vice President: This is an appeal by the assessee against the order dated 01.07.2025, passed by National Faceless Appeal Centre (‘NFAC’ for short), Delhi, pertaining to the assessment year (A.Y.) 2016-17. 2. Though, the assessee has raised multiple grounds, however, at the time of hearing, ld. Counsel

Neelkanth Realtors Limited, Mumbai vs. Income Tax Officer, Ward 3(2)(3), Mumbai

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

ITA 5206/MUM/2025[2017-2018]Status: DisposedITAT Mumbai17 Dec 2025AY 2017-2018

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2017-18 Neelkanth Realtors Limited, Income Tax Officer, 508, Dalamal House, Ward-3(2)(3), J.B. Marg, Vs. Maharshi Karve Road, Nariman Point, New Marinelines, Mumbai-400021. Mumbai-400020. Pan : Aaaca9796N (Appellant) (Respondent) For Assessee : Shri Pratik A. Mehta For Revenue : Shri Brajendra Kumar, Sr.Dr Date Of Hearing : 03-12-2025 Date Of Pronouncement : 17-12-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 31-07-2025, Pertaining To Assessment Year (Ay) 2017-18. 2. Briefly Stated, Facts Of The Case Are That The Assessee Filed Its Return Of Income Declaring Total Income Of Rs. 10,71,080/-, Which Was Selected For Scrutiny & Notices U/S. 143(2) & 142(1) Of The Income Tax Act, 1961 („The Act‟) Were Issued. In Response, The Assessee Filed Its Submissions From Time To Time, Thereafter The Assessment Order Was Passed By The Ao

For Appellant: Shri Pratik A. MehtaFor Respondent: Shri Brajendra Kumar, Sr.DR

Section 143(2)Section 143(3)Section 14A

This is an appeal filed by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi [„Ld.CIT(A)‟], dated 31-07-2025, pertaining to Assessment Year (AY) 2017-18. 2. Briefly stated, facts of the case are that the assessee filed

Flamingo Pharmaceuticals Ltd, Sion Trombay Road Chembur vs. DCIT Circle-14(1)(2), Mumbai, Aaykar Bhavan, M.K. Road

In the result, the appeal of the assessee is allowed

ITA 4952/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Dec 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Ravindra Poojary,ARFor Respondent: Ms. Kavitha Kaushik, (Sr.DR)

Section 143(3)Section 35

IN THE INCOME-TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT

ACIT, Mumbai vs. Reliance Power Ltd, Mumbai

ITA 3989/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Dec 2025AY 2016-17

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am Acit-15(3)(1), Aayakar Bhavan, Room No. 460, 4Th Floor, M.K. Road, Mumbai-400020. Vs. Revenue-अपीलार्थी / Appellant Assessee By Revenue By Date Of Hearing Date Of Pronouncement

Section 115JSection 14Section 143(3)Section 14ASection 37(1)

आयकर अपीलीय अधिकरण न्याय पीठ मुंबई में। IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI AMIT SHUKLA

Income Tax Officer/Ward-19(2)(2), Mumbai vs. Kruti Sandeep Shah, Mumbai

In the result, the appeal of the Revenue is disposed off in light of aforesaid directions

ITA 1968/MUM/2025[2009-10]Status: DisposedITAT Mumbai17 Dec 2025AY 2009-10

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2009-10 Income Tax Officer, Kruti Sandeep Shah, Ward-19(2)(2), 117, Navyug Nagar Forjet Hill 503, 5Th Floor, Vs. Road, Piramal Chambers, Mumbai-400007. Parel, [Pan: Aapps4121F] Mumbai-400012. (Appellant) (Respondent) For Assessee : Shri Sandeep Shah For Revenue : Shri Kiran K. Chhatrapati, Sr.Dr Date Of Hearing : 16-12-2025 Date Of Pronouncement : 17-12-2025 Order Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 23-01-2025, Pertaining To Assessment Year (Ay) 2009-10. 2. Briefly The Facts Of The Case Are That The Assessee Filed Her Return Of Income U/S. 139(1) Of The Income Tax Act, 1961 („The Act‟) On 26-09-2009, Declaring Total Income Of Rs. 4,04,880/-. The Return Was Processed U/S. 143(1) Of The Act. Subsequently, The Ao Was In Receipt Of Information From The Investigation Wing That The Assessee Has Obtained Accommodation

For Appellant: Shri Sandeep ShahFor Respondent: Shri Kiran K. Chhatrapati, Sr.DR

Section 139(1)Section 142(1)Section 143(1)Section 144Section 145(3)Section 148

This is an appeal filed by the Revenue against the order of the Learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi [„Ld.CIT(A)‟], dated 23-01-2025, pertaining to Assessment Year (AY) 2009-10. 2. Briefly the facts of the case are that the assessee filed

Mulchand Shamji Chheda HUF, Mumbai vs. Income Tax Officer -26(2)(3), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 1700/MUM/2025[2016-17]Status: DisposedITAT Mumbai17 Dec 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 194ASection 271BSection 40Section 44A

communicated or served on it for which the assessee wrote a letter dated 12.02.2020 to him regarding delay and sent several emails to NFAC with no response.It also sent communications to CBDT in this regard and only on 25.02.2025 the order was made available and the appeal could be filed

Western Industrial Co-Operative Estate Limited, Mumbai vs. DCIT Circle 32(1), Mumbai

In the result the appeal filed by the assessee in ITA No

ITA 6514/MUM/2024[2017-2018]Status: DisposedITAT Mumbai17 Dec 2025AY 2017-2018

Bench: Shri Saktijit Dey () & Shri Jagadish ()

Section 14(3)Section 194ISection 24Section 80P(2)(d)Section 80P(2)(e)

Jagadish, A.M.: Aforesaid appeals filed by the assessee for Assessment Year (AY) 2017-18 arises out of the order of National Faceless Appeal Centre (NFAC), Delhi [hereinafter “CIT(A)"] dated 15.10.2024 & 17.10.2024. ITA No. 6324/Mum/2024 2. The assessee has filed return of income showing total income of Rs.48

Western Industrial Co-Operative Estate Limited, Mumbai vs. ACIT, Circle 32(1), Mumbai

In the result the appeal filed by the assessee in ITA No

ITA 6324/MUM/2024[2017-2018]Status: DisposedITAT Mumbai17 Dec 2025AY 2017-2018

Bench: Shri Saktijit Dey () & Shri Jagadish ()

Section 14(3)Section 194ISection 24Section 80P(2)(d)Section 80P(2)(e)

Nikhil Vinod Raj Rathod Jain, Mumbai vs. Ward 23(2)(6), Mumbai

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

ITA 4709/MUM/2024[2012-13]Status: DisposedITAT Mumbai17 Dec 2025AY 2012-13

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2012-13 Nikhil Vinod Raj Rathod Jain, Income Tax Officer, 3Rd Floor, Ward-23(2)(6), Jitendra House, Vs. Piramal Chamber, 20/28, Marinelines, Mumbai. Mumbai-400002. Pan : Almpr4342P (Appellant) (Respondent) For Assessee : Shri Gourav Sharma (Virtually Present) For Revenue : Shri Rajesh Sakhardande, Sr.Dr Date Of Hearing : 03-12-2025 Date Of Pronouncement : 17-12-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 23-03-2024, Pertaining To Assessment Year (Ay) 2012-13. 2. At The Outset, It Is Noted That The Co-Ordinate Bench Of The Tribunal Has Passed An Order Dt. 23-12-2024, Dismissing The Appeal Of The Assessee On Account Of Non-Prosecution & The Said Order Was Subsequently

For Appellant: Shri Gourav SharmaFor Respondent: Shri Rajesh Sakhardande, Sr.DR

Section 143(2)Section 148Section 68

This is an appeal filed by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), Delhi [„Ld.CIT(A)‟], dated 23-03-2024, pertaining to Assessment Year (AY) 2012-13. 2. At the outset, it is noted that the Co-ordinate Bench

Income Tax Officer, Ward-44(1), Delhi vs. Savita Aggarwal, Delhi

ITA 800/DEL/2025[2015]Status: DisposedITAT Delhi17 Dec 2025

Bench: Shri Anubhav Sharma & Shri Amitabh Shuklaincome Tax Officer Vs. Savita Aggarwal Ward-44(1) A-147, Shankar Garden, Room No. 1804, 18Th Vikaspuri Floor, E-2 Block, Delhi – 110018 Spm Civic Centre Delhi – 110002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacpa3523A Appellant .. Respondent

For Appellant: Sh. Suresh K.Gupta, CAFor Respondent: Sh. Om Prakash, Sr. DR

Section 147Section 148Section 149(1)Section 68

ANUBHAV SHARMA, JM: This appeal is preferred by the assessee against the order dated 24.06.2024 of the Ld. National Faceless Appeal Centre (NFAC) Delhi P a g e | 2 Savita Aggarwal (AY: 2015-16) (hereinafter referred as Ld. First Appellate Authority or in short Ld. ‘FAA’) in DIN & Order

Geeta Behl, Delhi vs. ITO Ward 30(1), Delhi

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

ITA 6936/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Pawan Singh(Physical Hearing) Geeta Behl Ito, Ward 30(1), New Delhi E-54, Masjid Moth, Vs Civic Centre, New Delhi – 110002. Greater Kailash-2, South Delhi-110048. [Pan: Aahpb3714D] Appellant / Assessee Respondent / Revenue

Section 144Section 254(1)Section 270A

Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by assessee is directed against the order of ld. CIT(A) / NFAC dated 26.08.2025 for A.Y. 2017-18, wherein penalty levied under section 270A was upheld. 2. Rival submissions of both the parties have been heard and record perused

Adesh Kumar Gupta, Delhi vs. Income Tax Officer, Ward 62(1), Delhi

In the result, ground no. 2 & 3 of the appeal is partly

ITA 6930/DEL/2025[2019-20]Status: DisposedITAT Delhi17 Dec 2025AY 2019-20

Bench: Shri Pawan Singh(Physical Hearing) Adesh Kumar Gupta Ito, Ward-62(1), Delhi House No. 6, Sector -11, Pocket-C- Vs Civic Centre, Delhi – 110002. 5, Rohini, Delhi – 110085. [Pan: Aaipg9669H] Appellant / Assessee Respondent / Revenue

Section 145Section 147Section 254(1)Section 69C

Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by assessee is directed against the order of ld. CIT(A) / NFAC dated 10.09.2025 for A.Y. 2019-20. The assessee has raised following grounds of appeal: “1. The reassessment proceedings and consequent reassessment both are invalid and without jurisdiction

Prem Parkash Gupta, Delhi vs. ITO Ward 50(5), New Delhi

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

ITA 6863/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Pawan Singh(Physical Hearing) Premparkash Gupta Ito, Ward-50(5), Delhi Ea-156, Inderpuri, Delhi – 110012. Vs Room No. 1411, E2 Block, Civic [Pan: Aagpg5931L] Centre, New Delhi – 110002. Appellant / Assessee Respondent / Revenue

Section 115BSection 131Section 254(1)Section 44ASection 68Section 69A

Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by assessee is directed against the order of ld. CIT(A) / NFAC dated 25.08.2025 for A.Y. 2017-18. The assessee has raised following grounds of appeal: “1. The facts and circumstances of subject, the learned CIT(A), NFAC ... facts and circumstances of the case as well as law on the subject, the learned CIT(A), NFAC has erred in confirming the action of Assessing Officer in invoking provisions of Section 115BBE of the Act and in thereby taxing entire unexplained cash credits at 60 percentages and levying surcharge

Sat Narain Sharma, Rohtak vs. Ward 2, Rohtak

In the result, appeal of the assessee is allowed

ITA 6167/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Pawan Singh(Physical Hearing) Sat Narayan Sharma Ward-2, Rohtak Village & Post Office Bohar, Dist. Vs Aayakarbhawan, Rohtak, Rohtak, Haryana – 124021. Haryana – 124001. [Pan: Afjps5702B] Appellant / Assessee Respondent / Revenue

Section 147Section 148Section 148ASection 234ASection 254(1)

Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by assessee is directed against the order of ld. CIT(A) / NFAC dated 25.08.2025 for A.Y. 2017-18. The assessee has raised following grounds of appeal: “1. The order of the id. Commissioner of Income Tax (Appeals) NFAC ... facts. 2. On the facts and circumstances of the case, the Id. Commissioner of Income Tax (Appeals) NFAC has erred both on facts and in law in confirming the order passed by the Assessing Officer for initiating proceedings u/s 147 of the Income Tax Act despite the same being initiated

Bansal Industries, Hansi vs. ITO Ward 1 Hissar, Hissar

In the result, the appeal filed by the assessee for A

ITA 5404/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Dec 2025AY 2016-17

Bench: Shri C.N. Prasad

Section 143(2)Section 147Section 148Section 151

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘SMC’: NEW DELHI BEFORE SHRI C.N. PRASAD, JUDICIAL MEMBER ITA No.5395 & 5404/Del/2025