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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

Mr. Bharat Natwarlal Dave, Nadiad Kheda vs. ITO Ward 1, Dhule

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

ITA 289/PUN/2025[2013-14]Status: DisposedITAT Pune28 Nov 2025AY 2013-14

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.289/Pun/2025 निर्धारण वषा / Assessment Year: 2013-14 Mr.Bharat Natwarlal Dave, V The Income Tax Officer, A/5 Harikunj Society, S Ward-1, Dhule. Opp.Sanket Society, Vaishali Cinema Road, Nadiad Kheda, Gujarat – 387002. Pan: Ahkpd0928P Appellant/ Assessee Respondent / Revenue Assessee By Shri Aakash Parakh Revenue By Shri Manish M. Mehta Date Of Hearing 06/11/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2013-14 On 01.12.2021 Emanating From Penalty Order U/S.271(1)(C) Of The Act, Dated 21.06.2019 Which In Turn Arises From Assessment Order Dated 24.12.2018. Ita No.289/Pun/2025 [A] Findings & Analysis : 2. We Have Heard Both The Parties & Perused The Records. In This Case, Penalty U/S.271(1)(C) Of The Act, Has Been Levied For A.Y.2013-14 On 21.06.2019. In This Case, It Is Mentioned In The Penalty Order That Assessment Order Was Passed U/S.144 R.W.S 147 Of The Income Tax Act, Determining Total Income At Rs.12,66,840/- Vide Assessment Order Dated 24.12.2018. 3. It Has Been Brought To Our Notice That The Assessee’S Appeal Against Assessment Order Has Been Set-Aside By Itat To Ld.Cit(A) For Denovo Adjudication. We Have Gone Through The Itat Pune Bench Decision In Ita No.288/Pun/2025 For A.Y.2013-14, Wherein

Section 144Section 250Section 271(1)(c)

ORDER PER DR. DIPAK P. RIPOTE, AM: This is an appeal filed by the Assessee against the order of ld.Commissioner of Income Tax(Appeal)[NFAC] passed under section 250 of the Income Tax Act, 1961 for A.Y.2013-14 on 01.12.2021 emanating from penalty order u/s.271(1)(c) of the Act, dated

Shrimadurjit Seva Kendra, Pune vs. The ITO, Ward 8(3), Pune

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

ITA 2276/PUN/2025[2013-2014]Status: DisposedITAT Pune28 Nov 2025AY 2013-2014

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2276/Pun/2025 निर्धारण वषा / Assessment Year: 2013-14 Shrimadurjit Seva Kendra, V The Income Tax Officer, S.No.117/1, Chowisawdi, S. Ward-8(3), Pune. Haveli, Pune – 412105. Pan: Absfs4340L Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Amit Bobde –Cit(Dr) Date Of Hearing 19/11/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: In This Case, Appeal Has Been Filed By The Assessee Against The Order Of Ld.Additional/Joint Commisioner Of Income Tax(Appeal), Panaji Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2013-14 Dated 31.07.2025. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Learned Addl./Jt.Cit(A), Panaji Erred In Law & On Facts In Dismissing Appellant'S Appeal Without Granting Sufficient Opportunity Of Being Heard. Appellant Assures To Make All The Compliances Before The

Section 200ASection 220(2)Section 234ESection 246ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)

filed. Submission of ld.Departmental Representative(ld.DR) : 3. The ld.DR for the Revenue relied on the order of Assessing Officer(AO) and ld.CIT(A)[NFAC]. ITA No.2276/PUN/2025 [A] Findings & Analysis : 4. We have heard ld.DR for the Revenue and perused the records. Ld.CIT(A) has held as under : “1. Despite granting

Savita Mitkari, Pune vs. Income Tax Officer, Pune

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

ITA 2193/PUN/2025[2011-12]Status: DisposedITAT Pune28 Nov 2025AY 2011-12

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.2193/Pun/2025 निर्धारण वर्ष / Assessment Year: 2011-12 Savita Mitkari, V The Income Tax Officer, Flat No.302, G4, Gangadham S Pmt Phase Ii, Market Yard, Building Pune 411037. Commercial Complex, Swargate, Pune 411037. Pan: Arppm8052L Appellant/ Assessee Respondent / Revenue Assessee By Ca Sagar Kale Shri Arvind Renge – Addl.Cit(Dr) Revenue By Date Of Hearing 06/11/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal) [Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2011-12 Dated 30.07.2025 Emanating From The Assessment Order Passed Under Section 143(3) R.W.S 147 Of The Act, Dated 30.12.2018. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 147Section 250Section 68

ORDER PER DR. DIPAK P. RIPOTE, AM: This is an appeal filed by the Assessee against the order of ld.Commissioner of Income Tax(Appeal) [NFAC] passed under section 250 of the Income Tax Act, 1961 for the A.Y.2011-12 dated 30.07.2025 emanating from the Assessment Order passed under section ... assessee. Submission of ld.Departmental Representative(ld.DR) : 3. The ld.DR for the Revenue relied on the order of Assessing Officer(AO) and ld.CIT(A)[NFAC]. Findings & Analysis : 4. We have heard both the parties and perused the records. Ld.CIT(A) has held as under : “From the conduct of the appellant

The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd, Satara vs. ACIT, Satara, Cir-Satara

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

ITA 2156/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.2155 & 2156/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd., Ajinkya Complex, 512, Ch. Shivaji Road, Camp, Sadar Bazar, Satara-415001 Asst. Commissioner Of Income Tax, Satara Circle, Vs. Satara Pan: Aaaat1502B अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Ms. Renuka Arunrao Ghatge Shri S. Sadananda Singh 11-11-2025 28-11-2025 आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 15.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”/“Nfac"] Pertaining To Assessment Year (“Ay") 2020-21. For The Sake Of Convenience, Both These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing
Section 139(1)Section 143(2)Section 144Section 41(1)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(b)Section 80P(2)(d)

assessee are directed against the separate orders both dated 15.07.2025 of the Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi [“CIT(A)”/“NFAC"] pertaining to Assessment Year (“AY") 2020-21. For the sake of convenience, both these appeals were heard together and are being disposed of by this common order ... assessee has raised the following grounds of appeal :- "1. On the facts and in the circumstances of the case and in law, the Ld. NFAC-CIT (A), Delhi, has erred in confirming the action of Ld. Assessing officer (A.O.) in making addition of Rs.1,11,08,542/- on account

The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd, Satara vs. ACIT, Satara, Cir-Satara

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

ITA 2155/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.2155 & 2156/Pun/2025 निर्धारण वर्ष / Assessment Year : 2020-21 The Satara Zilla Krishi Bank Karmachari Sahakari Patsanstha Ltd., Ajinkya Complex, 512, Ch. Shivaji Road, Camp, Sadar Bazar, Satara-415001 Pan: Aaaat1502B अपीलार्थी / Appellant Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Asst. Commissioner Of Income Tax, Satara Circle, Vs. Satara प्रत्यर्थी / Respondent Ms. Renuka Arunrao Ghatge Shri S. Sadananda Singh 11-11-2025 28-11-2025 आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 15.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi [“Cit(A)”/“Nfac"] Pertaining To Assessment Year (“Ay") 2020-21. For The Sake Of Convenience, Both These Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

For Appellant: Department byFor Respondent: Date of hearing
Section 139(1)Section 143(2)Section 144Section 41(1)Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(b)Section 80P(2)(d)

assessee are directed against the separate orders both dated 15.07.2025 of the Ld. Commissioner of Income Tax (Appeals)/NFAC, Delhi [“CIT(A)”/“NFAC"] pertaining to Assessment Year (“AY") 2020-21. For the sake of convenience, both these appeals were heard together and are being disposed of by this common order ... assessee has raised the following grounds of appeal :- "1. On the facts and in the circumstances of the case and in law, the Ld. NFAC-CIT (A). Delhi, has erred in confirming the action of Ld. Assessing officer (A.O.) in making addition of Rs.1,11,08,542/- on account

Shree Vishal Jewellers, Pune vs. DCIT Circle 9 Pune, Akurdi Pune

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

ITA 1975/PUN/2025[2017-18]Status: DisposedITAT Pune28 Nov 2025AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1975/Pun/2025 धििाारण वर्ा / Assessment Year : 2017-18 Shree Vishal Jewellers, Dcit, Circle-9, Pune Kohinoor Arcade, Nigdi, Pune-411044 Vs. Pan : Achfs8052R अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Sushant Padhye Department By : Shri Udaya Bhaskar Jakke Date Of Hearing : 11-11-2025 Date Of 28-11-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 14.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. Error In Additions Of Rs.6,25,94,300/- In Respect Of Provision Of Section 68 Of The Act. The Ao Erred In Appreciating The Complexity Of Assessee'S Business & Made Addition Based On Conjecture Rather Than Evidence. Addition Was Made Merely By Treating Excess Balance Of Cash As Unexplained Credits Thereby Ignoring The Circumstances In Which Such Cash Was Recorded. 2. Error In Additions Of Rs.82,96,610/- In Respect Of Provision Of Section 68 Of The Act. The Ao Made An Addition In Haste Without Completely Understanding The Facts Of The Case. This Addition Belies A Sense Of Proportion. A. Addition Of Rs.46,96,610/- Of Unsecured Loan Forwarded By Mrs. Sangeeta Sonigara: The Officer Erred In Appreciating The Fact That The Loan Could Have Been Given By The Said Person From Gifts Received Or Through Other Exempt Income Earned In The Past. Merely Because The Person Doesnt Not Have Sufficient Income In The Immediately Previous Years Does Not Invalidate The Genuineness Of The Unsecured Loan. B. Addition Of Rs.37,00,000/- Of Unsecured Loan Forwarded By Mr. Ganesh Nadha: The Said Person Is A Third Party. Unsecured

For Appellant: Shri Sushant PadhyeFor Respondent: Shri Udaya Bhaskar Jakke
Section 143(2)Section 143(3)Section 250Section 68

ASTHA CHANDRA, JM : The appeal filed by the assessee is directed against the order dated 14.07.2025 of the Ld. Commissioner of Income Tax (Appeals), NFAC, Delhi [“CIT(A)/NFAC”] pertaining to Assessment Year (“AY”) 2017-18. 2. The assessee has raised the following grounds of appeal :- “1. Error in additions ... admitted fact that despite number of opportunities granted, the assessee did not make any submission for which the Ld. CIT(A) / NFAC dismissed the appeal filed by the assessee. The Ld. AR has submitted that such non- compliance was not intentional but resulted on account of the reasons cited above

Br Nath Pai Shikshan Sanstha, Kudal vs. ITO, Exemption, Exemption Ward

In the result the appeal filed by the assessee in ITA

ITA 1785/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1782, 1783 & 1785/Pun/2025 निर्धारण वर्ष / Assessment Years : 2020-21 To 2022-23 Br Nath Pai Shikshan Vs. Cpc, Bangalore. Sanstha, Plot No.4, Midc, Near Vayman Garden Compound, Sindhudurg- 416520. Appellant Respondent Pan: Aabtb1496N Assessee By : Shri P. P. Jayaraman Revenue By : Smt. N. C. Shilpa Date Of Hearing : 19.11.2025 Date Of Pronouncement : 28.11.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2025 Passed By Ld. Addl./Jcit(A)-6, Kolkata ['Ld. Cit(A)'] For The Assessment Years 2020-21 To 2022-23 Respectively. 2. Since Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1785/Pun/2025 For A.Y. 2020-21 As The Lead Case For Adjudication.

For Appellant: Shri P. P. JayaramanFor Respondent: Smt. N. C. Shilpa
Section 11Section 12ASection 143(1)

demand of Rs.8,59,78,930/-. 5. Being aggrieved, the assessee preferred an appeal before the Commissioner of Income Tax, National Faceless Appeal Centre (NFAC) who vide order dated 09.08.2023 dismissed the appeal filed by the assessee. The assessee, therefore, preferred an appeal before the Tribunal who by impugned order

Br Nath Pai Shikshan Sanstha, Kudal vs. ITO, Exemption

In the result the appeal filed by the assessee in ITA

ITA 1783/PUN/2025[2021-22]Status: DisposedITAT Pune28 Nov 2025AY 2021-22

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1782, 1783 & 1785/Pun/2025 निर्धारण वर्ष / Assessment Years : 2020-21 To 2022-23 Br Nath Pai Shikshan | Vs. Cpc, Bangalore. Sanstha, Plot No.4, Midc, Near Vayman Garden Compound, Sindhudurg- 416520. Pan: Aabtb1496N Appellant Respondent Assessee By : Shri P. P. Jayaraman Revenue By : Smt. N. C. Shilpa Date Of Hearing : 19.11.2025 Date Of Pronouncement : 28.11.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2025 Passed By Ld. Addl./Jcit(A)-6, Kolkata ['Ld. Cit(A)'] For The Assessment Years 2020-21 To 2022-23 Respectively. 2. Since Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1785/Pun/2025 For A.Y. 2020-21 As The Lead Case For Adjudication.

For Appellant: Shri P. P. JayaramanFor Respondent: Smt. N. C. Shilpa
Section 11Section 12ASection 143(1)

demand of Rs.8,59,78,930/-. 5. Being aggrieved, the assessee preferred an appeal before the Commissioner of Income Tax, National Faceless Appeal Centre (NFAC) who vide order dated 09.08.2023 dismissed the appeal filed by the assessee. The assessee, therefore, preferred an appeal before the Tribunal who by impugned order

Br Nath Pai Shikshan Sanstha, Kudal vs. ITO, Exemption, Exemption Ward

In the result the appeal filed by the assessee in ITA

ITA 1782/PUN/2025[2022-23]Status: DisposedITAT Pune28 Nov 2025AY 2022-23

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1782, 1783 & 1785/Pun/2025 निर्धारण वर्ष / Assessment Years : 2020-21 To 2022-23 Br Nath Pai Shikshan Vs. Cpc, Bangalore. Sanstha, Plot No.4, Midc, Near Vayman Garden Compound, Sindhudurg- 416520. Pan: Aabtb1496N Appellant Respondent Assessee By : Shri P. P. Jayaraman Revenue By : Smt. N. C. Shilpa Date Of Hearing : 19.11.2025 Date Of Pronouncement : 28.11.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 05.06.2025 Passed By Ld. Addl./Jcit(A)-6, Kolkata ['Ld. Cit(A)'] For The Assessment Years 2020-21 To 2022-23 Respectively. 2. Since Identical Facts & Common Issues Are Involved In The Above Captioned Three Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1785/Pun/2025 For A.Y. 2020-21 As The Lead Case For Adjudication.

For Appellant: Shri P. P. JayaramanFor Respondent: Smt. N. C. Shilpa
Section 11Section 12ASection 143(1)

demand of Rs.8,59,78,930/-. 5. Being aggrieved, the assessee preferred an appeal before the Commissioner of Income Tax, National Faceless Appeal Centre (NFAC) who vide order dated 09.08.2023 dismissed the appeal filed by the assessee. The assessee, therefore, preferred an appeal before the Tribunal who by impugned order

Vikram Digvijay Kapadia L/H Late Shri. Digvijay Babubhai Kapadia, Nashik vs. ACIT Circle 1, Nashik

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

ITA 1730/PUN/2025[2018-19]Status: DisposedITAT Pune28 Nov 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकरअपऩलसं. / Ita No.1730/Pun/2025 निर्धारणवषा / Assessment Year: 2018-19 Vikram Digvijay Kapadia V Acit, Legal Heir Of Late Shri S. Circle-1, Nashik. Digvijay Babubhai Kapadia, Babubhai House, Kulkarni Colony, Sharanpur Road, Nashik – 422002. Maharashtra. Pan: Afzpk8616E Appellant/ Assessee Respondent / Revenue Assessee By Ca Chinmayy Pathak – (Virtual) Revenue By Smt. Saumya Pandey Jain- Addl.Cit(Dr) Date Of Hearing 18/11/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed Legal Heir Mr.Vikram Digvijay Kapadia Of Late Shri Digvijay Babubhai Kapadia Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2018-19 On 10.04.2024 Emanating From Assessment Order U/S.143(3) Dated

Section 10Section 10(34)Section 10(35)Section 143(3)Section 250

appeal filed Legal Heir Mr.Vikram Digvijay Kapadia of Late Shri Digvijay Babubhai Kapadia against the order of ld.Commissioner of Income Tax(Appeal)[NFAC] passed under section 250 of the Income Tax Act, 1961 for A.Y.2018-19 on 10.04.2024 emanating from Assessment Order u/s.143(3) dated ITA No.1730/PUN/2025 [A] 06.04.2021. The Assessee