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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

M/S. Mithilesh Fabrics, Tirupur vs. ITO, Ward 1(1), Tirupur, Triupur

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

ITA 3124/CHNY/2025[2017-18]Status: DisposedITAT Chennai10 Mar 2026AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.3124/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 M/S. Mithilesh Fabrics, Vs. The Income Tax Officer, No. 19, Elango Nagar, 3Rd Street, Ward 1(1), Backside Sanat Theatre, Tirupur. Tirupur 641 602. [Pan: Abbfm7917J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri H. Yeshwanth Kumar, Advocate ""थ" की ओर से/Respondent By : Ms. T. Mythili, Jcit सुनवाई की तारीख/ Date Of Hearing : 03.02.2026 घोषणा की तारीख /Date Of Pronouncement : 10.03.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22.07.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 35 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We Find The Reasons Stated By The Assessee Are Bonafide, Which Really

For Appellant: Shri H. Yeshwanth Kumar, AdvocateFor Respondent: Ms. T. Mythili, JCIT
Section 147Section 148Section 69A

filed by the assessee is directed against the order dated 22.07.2025 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment year 2017-18. 2. We find that this appeal is filed with a delay of 35 days. The assessee filed

Coimbatore Nagarajan Paramasivan, Chennai vs. ITO, Ncc-10(1), Chennai

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

ITA 1896/CHNY/2025[2013-14]Status: DisposedITAT Chennai10 Mar 2026AY 2013-14

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1896/Chny/2025 िनधा"रण वष"/Assessment Year: 2013-14 Coimbatore Nagarajan Paramasivan, Vs. The Income Tax Officer, No. 23, Ttk Road, 1St Cross Street, Non Corporate Circle 10(1), Alwarpet, Chennai 600 018. Chennai. [Pan: Aagpp8933M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Abhishek Murali, C.A. (Virtual) ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 10.03.2026 घोषणा की तारीख /Date Of Pronouncement : 10.03.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2013-14. 2. When The Appeal Was Taken Up For Hearing, The Ld. Ar Shri Abhishek Murali, Ca, On Behalf Of The Assessee, Prayed For Withdrawal Of The Appeal, Against Which, The Ld. Dr Ms. R. Anita, Addl., Cit Has Not 2

For Appellant: Shri Abhishek Murali, C.A. (Virtual)For Respondent: Ms. R. Anita, Addl. CIT

filed by the assessee is directed against the order dated 28.05.2025 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment year 2013-14. 2. When the appeal was taken up for hearing, the ld. AR Shri Abhishek Murali, CA, on behalf

Rohit Bohara, Mumbai vs. DCIT, Circle 27(3), Mumbai

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

ITA 9333/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Rohit Bohra, Dcit-Circle27(3), B-3501, Bhagwati Eleganza, Vs Room No. 423, Vrccl, Plot No. 12, Sector 11, Ghansoli, Sector 30, Navi Mumbai, Navi Mumbai – 400709. Vashi – 400703. [Pan No. Ahqpb6511] Appellant / Assessee Respondent / Revenue Assessee By Shri Aditya Ramachandran, Ca Revenue By Shri Ujjwal Kumar – Sr. Dr Date Of Hearing 10.03.2026 Date Of Pronouncement 10.03.2026 Order Under Section 254(1) Of Income Tax Act Per: Pawan Singh: 1. This Appeal By The Assessee Is Directed Against The Order Of Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi (In Short, The Ld. Cit(A)) Dated 09/10/2025 For The Assessment Year (Ay) 2019-20. The Assessee Has Raised Following Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case & In Law, The Appeal Of The Appellant Before The Cit (A) May Please Be Restored Back & The Non-Compliance Of The Appellant In Respect Of The Notices Issued By The Cit (A) May Please Be Excused As It Was For The Genuine Reasons. 2. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A)/Nfac Erred In Confirming The Action Of The Ld. Assessing Officer In Adding Time Deposits Amounting To Rs 10,00,000 Under Section 69 Of The Act On The Ground That The Appellant Was Unable To Prove Its Corresponding Source. Rohit Bohra

Section 254(1)Section 69Section 80C

JUDICIAL MEMBER: 1. This appeal by the assessee is directed against the order of learned Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi (in short, the ld. CIT(A)) dated 09/10/2025 for the Assessment Year (AY) 2019-20. The assessee has raised following grounds of appeal

Sunil Suresh Rane, Dombivli vs. ITO Ward 42(3)(4), Mumbai

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

ITA 7729/MUM/2025[2016-17]Status: DisposedITAT Mumbai10 Mar 2026AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarsunil Suresh Rane Vs. Ito Ward 42(3)(4) 301 Amrita, Apts, Rajaji Kautilya Bhawan C41- Path Lane 43, Avenue 3, Near No.4 Dombivli Videsh Bhavan, G Block Mumbai - 421201 Bkc, Gilban Area, Bkc, Bandra East Mumbai - 400051 Pan/Gir No. Abtpr2589P (Applicant) (Respondent) Assessee By Shri Aakash Parekh (Virtually Present) Revenue By Shri Brajendra Kumar (Sr. Dr) Date Of Hearing 12.02.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 29.09.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2016-17. The Following Grounds Are Reproduced Below: “1. Ground No. 1: Gross Violation Of Principles Of Natural Justice

Section 144BSection 147Section 148Section 149(1)(b)Section 250Section 250(6)Section 251

assessee challenging the impugned order 29.09.2025 passed u/s 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre, Delhi (NFAC) for the assessment year 2016-17. The following grounds are reproduced below: “1. Ground No. 1: Gross Violation of Principles of Natural Justice ... consequential reassessment deserves to be quashed. 5.4. On the facts and in the circumstances of the case and in law, Ld. NFAC has erred in upholding the illegal order passed by the Ld. NaFAC since the Notice u/ 148 dated 16-03-2023 was issued by Jurisdictional Assessing Officer

Dattatray Vithoba Sawant, Kalyan vs. Income Tax Officer, WD-42(2)(2), Mumbai

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

ITA 6080/MUM/2025[2015-16]Status: DisposedITAT Mumbai10 Mar 2026AY 2015-16

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankardattatray Vithoba Sawant Vs. Income Tax Officer, Wd- D7, 1103, Rounak City, 42(2)(2) Sector-4, Khadakpada, Kautilya Bhavan, Kalyan-West, Kalyan- Bandra Kurla Complex, 421301 Mumbai-400051 Pan/Gir No. Aclps7508Q (Applicant) (Respondent) Assessee By Shri Jay Thakkar Revenue By Shri Brajendra Kumar (Sr. Dr.) Date Of Hearing 10.02.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 28.07.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2015-16. The Following Grounds Are Reproduced Below: “Additional Grounds Raised For The 1" Time 1.0 On Facts & Circumstances Of The Case & In Law, The Re-Assessment Order Passed U/S.147 Dated 21/09/2021 By National Faceless Assessment Centre (Nfac) Is Bad-In- Law, Since The Scheme For Faceless Assessment Of Income

Section 144BSection 147Section 151ASection 250Section 80CSection 80G

assessee challenging the impugned order 28.07.2025 passed u/s 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre, Delhi (NFAC) for the assessment year 2015-16. The following grounds are reproduced below: “Additional Grounds raised for the 1" time 1.0 On facts and circumstances ... case and in law, the re-assessment order passed u/s.147 dated 21/09/2021 by National Faceless Assessment Centre (NFAC) is bad-in- law, since the Scheme for Faceless assessment of income 2 Dattatray Vithoba Sawant escaping assessment prescribed u/s.151A had been notified by the CBDT w.e.f. 29/03/2022; 2.0 On facts

Deputy Commissioner of Income Tax Central Circle 5(3), Mumbai vs. Sanghvi Dhanrupji Devaji & Co., Mumbai

In the result, the appeal filed by the revenue stands dismissed

ITA 6015/MUM/2025[AAQFS6338H]Status: DisposedITAT Mumbai10 Mar 2026

Bench: Hon’Ble Shri Sandeep Gosain& Hon’Ble Shri Bijayananda Prusethdeputy Commissioner Of Vs. Sanghvi Dhanrupji Income Tax Central Circle Devaji & Co. 5(3), Mumbai 33, Mumba Devi Road, Room No. 426, 4Th Floor, Dagina Bazar, Kautilya Bhavan, Mumbai- 400002 Mumbai- 400051 Pan/Gir No. Aaqfs6338H (Applicant) (Respondent) Assessee By Shri M B Sanghvi Revenue By Ms. Kavitha Kaushik,Sr.Dr. Date Of Hearing 21.01.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Revenue Challenging The Impugned Order Dated 23.12.2024 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2014-15. The Revenue Has Raised The Following Grounds Of Appeal: 1. Ground I - Whether On The Facts & The Circumstances Of The Case & In Law, The Cit(A) Erred In Deleting/Allowing Relief In Respect Of The Addition Of Rs.

Section 250Section 40A(3)(a)Section 68

challenging the impugned order dated 23.12.2024 passed u/s 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre, Delhi (NFAC) for the assessment year 2014-15. The revenue has raised the following grounds of appeal: 1. Ground I - Whether on the facts and the circumstances

Bhagawati M Jain, Dombivali vs. Ward 3(1), Kalyan

In the result, appeal of the assessee is allowed

ITA 2408/MUM/2025[2018-2019]Status: DisposedITAT Mumbai10 Mar 2026AY 2018-2019

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2018-19 Bhagawati M Jain Income Tax Officer C-22, Bhanu Chs, Ward 3(1), Bhanu Nagar, Dombivali East, 2Nd Floor, Rani Mansion, Vs. Kalyan - 421201 Kalyan-Murbad Rd, Maharashtra Kalyan-Dombivali, Maharashtra, 421301 (Pan: Aatpj1123G) (Appellant) (Respondent) Present For: Assessee : Shri Viraj Mehta, Ca Revenue : Shri Aditya Rai, Sr. Dr Date Of Hearing : 22.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2024-25/1073449956(1), Dated 19.02.2025, Passed Against The Assessment Order By Assessing Officer, National Faceless Assessment Centre, Delhi, U/S. 147 R.W.S.144B Of The Income- Tax Act (Hereinafter Referred To As The “Act”), Dated 26.02.2024, For Assessment Year 2018-19. 2. Grounds Taken By Assessee Are Reproduced As Under:

For Appellant: Shri Viraj Mehta, CAFor Respondent: Shri Aditya Rai, Sr. DR
Section 132Section 139(1)Section 147Section 148Section 148ASection 151Section 153CSection 69B

GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the order of National Faceless Appeal Centre (NFAC), Delhi, vide order no. ITBA/NFAC/S/250/2024-25/1073449956(1), dated 19.02.2025, passed against the assessment order by Assessing Officer, National Faceless Assessment Centre, Delhi, u/s. 147 r.w.s.144B of the Income- tax Act (hereinafter

Santram, Dehradun vs. ITO Ward 1(1)(3), Dehradun

In the result, the appeal of the assessee is allowed

ITA 3/DDN/2026[2017-18]Status: HeardITAT Dehradun09 Mar 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2017-18] Santram Vs Ito Near Subhash Chandra Ward-1(1)(3) Bose Academy, Nathuwala, Dehradun Dehradun-248001. Pan-Demps4349P Appellant Respondent Appellant By Shri Rajiv Sahni, Ca Respondent By Ms. Poonam Sharma, Cit Dr Date Of Hearing 09.03.2026 Date Of Pronouncement 09.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 24.12.2025 Passed By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld. Cit(A)”] U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Penalty Order Dated 24.03.2025 Passed U/S 270A Of The Act Pertaining To Assessment Year 2017-18. 2. Heard The Contentions Of Both Parties & Perused The Material Available On Record. It Is Stated By Ld. Ar That The Quantum Appeal Filed By The Assessee For The Captioned Assessment Years Against The Assessment Order Passed Has Already Been Restored Back To The File Of The Ao By The Tribunal Passing For Denovo Assessment Vide Its Order Passed In Ita No.57/Ddn/2025 For Assessment Year 2017-18 Dt. 09.07.2025. Thus, The Current Penalty Proceedings Initiated In The Said Order Has No Legs To Stand. Accordingly, We Delete The Penalty So Levied. The Ao Is At Liberty To Initiate The Proceedings, If Desired, In The Set Aside Proceedings In Accordance With Law. With These Directions, Appeal Filed By The Assessee Is Allowed.

Section 250Section 270A

MANISH AGARWAL, AM : The present appeal is filed by assessee against the order dated 24.12.2025 passed by Ld. Commissioner of Income Tax (A), NFAC, Delhi [“Ld. CIT(A)”] u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of penalty order dated 24.03.2025 passed u/s 270A