“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

Murugan Deepan, Chennai vs. DCIT, Ncc-10(1), Chennai

In the result, the appeal of the assessee is Partly Allowed

ITA 1988/CHNY/2025[2018-19]Status: DisposedITAT Chennai16 Oct 2025AY 2018-19

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:1988/Chny/2025 यनिाारणवर्ा / Assessment Year:2018-19 Murugan Deepan Deputy Commissioner Of No.33/20, Vs. Income Tax, Old Mahabalipuram Road, Non-Corporate Circle-10(1) Chennai-600 096. Chennai. [Pan:Ajwpd7671H] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr.N.Arjun Raj, Advocate प्रत्यर्थीकीओरसे/Revenue By : Ms.R.Anitha, Addl.Cit

For Appellant: Mr.N.Arjun Raj, AdvocateFor Respondent: Ms.R.Anitha, Addl.CIT

BALAGANESH, AM : This appeal by the assessee is filed against the order of the learned Commissioner of Income Tax (Appeal), NFAC, Delhi, (in short Ld.CIT(A) for the assessment year 2018-19, vide order dated 11.09.2024. ITA. No:1988/Chny/2025 2.0 At the outset, we find that there is a delay

Ramsamy Pongianna Gounder Desamani, Pallipalayam vs. Itd, Ward 2, Tiruchengode

ITA 2438/CHNY/2024[2011-12]Status: DisposedITAT Chennai16 Oct 2025AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:2438/Chny/2024 निर्धारण वर्ष / Assessment Year: 2011-12 Late. Ramasamy Pongianna Gounder Desamani, (Represented By Legal Heir Shri. P.D.Balachandhran) 79, R.P.Street, Sankari Bye-Pass Road, R.P.Street,\Pallipalayam – 638 006. [Pan:Acqpd-3208-H] (अपीलार्थी/Appellant) Ito, Vs. Ward -2, Tiruchengode. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By : Shri. T. S. Lakshmi Venkataraman, F.C.A. : Ms. Gauthami Manivasagam, J.C.I.T. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 09.09.2025 : 16.10.2025 आदेश /Order Per S. R. Raghunatha, Am: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, [Herein After “Ld. Cit(A)] Dated 16.07.2024 & Pertains To Assessment Year 2011-12. :-2-:

For Respondent: Shri. T. S. Lakshmi Venkataraman, F.C.A

Section 139Section 147Section 148Section 151Section 2(22)(e)Section 250

This appeal filed by the assessee is directed against the order passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, [herein after “ld. CIT(A)] dated 16.07.2024 and pertains to assessment year 2011-12. :-2-: ITA. No.:2438/Chny/2024 2. The assessee has raised ... other submissions to be made at the time of appeal hearing, the order U/S 250 passed by the Commissioner of Income Tax (Appeals), NFAC may be cancelled and justice rendered”. In brief, the solitary issue raised by the assessee in the present appeal is that

Dodda Ganapathi Mallikarjuna Swamy Devastana, Bangalore vs. Income Tax Officer, Ward-5(2)(1), Bangalore

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

ITA 718/BANG/2025[2018-19]Status: DisposedITAT Bangalore16 Oct 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

For Appellant: Shri Siddesh Gaddi, CAFor Respondent: Shri Balusamy N, JCIT (DR)

Section 10Section 11

WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the Revenue against the order passed by the NFAC, Delhi vide order dated 04/02/2025 in DIN No.ITBA/NFAC/S/250/2024-25/1072891530(1) for the assessment year 2018-19. 2. This appeal was heard with the assistance of the learned counsel for the assessee

Evehans Academy, Bangalore vs. Income Tax Officer, (Exemptions), Ward-1, Bangalore

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

ITA 362/BANG/2025[2018-19]Status: DisposedITAT Bangalore16 Oct 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2018-19

For Appellant: Shri Narendra Kumar J Jain, AdvocateFor Respondent: Dr. Thejaswi GV, JCIT (DR)

Section 11(2)

Ravikumar Krishnamurthy, Kolar vs. Income Tax Officer, Ward-1, Kolar

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

ITA 1519/BANG/2025[2017-18]Status: DisposedITAT Bangalore16 Oct 2025AY 2017-18

Bench: Shri Waseem Ahmedassessment Year: 2017-18

For Appellant: Shri R Chandrashekar, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 250

WASEEM AHMED, ACCOUNTANT MEMBER: This is an a ppeal filed by the assessee against the order of the NFAC, Delhi vide order dated 20/12/2024 in DIN No.ITBA/NFAC/S/250/2024- 25/1071413225(1) for the assessment year 2017-18. 2. At the outset, we note that the assessee has filed an affidavit explaining ... filing the present appeal. It is stated therein that the order passed under section 250 of the Act for AY 2017-18 by the NFAC was uploaded on the e-filing portal on 20.12.2024, but no intimation was received by the assessee. The assessee has explained that he had opted

Naresh Bansilal Jain, Mumbai vs. Income Tax Officer, Ward 20(1)(1) Mumbai, Mumbai

In the result, the appeal of the assessee is allowed for 4

ITA 643/MUM/2025[2021-2022]Status: DisposedITAT Mumbai16 Oct 2025AY 2021-2022

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry () Assessment Year: 2021-22

For Appellant: Mr. Satyaprakash SinghFor Respondent: 04/09/2025

Section 132(4)Section 56(2)(x)

bearing bearing bearing No.ITBA/NFAC/S/250/2024 No.ITBA/NFAC/S/250/2024-25/1071984171[1] passed by the 25/1071984171[1] passed by the Honourable Honourable Honourable CIT[Appeal], CIT[Appeal], CIT[Appeal], NFAC, NFAC, NFAC, Delhi, Delhi, Delhi, is is is excessive, excessive, excessive, unreasonable, arbitrary, against the provisions of Income Tax unreasonable, arbitrary, against the provisions

Income Tax Officer(Exmp)-2(4), Mumbai vs. Vishnu Janardan Shirolkar Mahajan Wady Trust, Mumbai

In the result, grounds of appeal raised

ITA 4919/MUM/2025[2022-23]Status: DisposedITAT Mumbai16 Oct 2025AY 2022-23

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri Kinjal Bhuta, A/RFor Respondent: Ms. Kavitha Kaushik, Sr. D/R

Section 11Section 11ASection 12A

। आयकर अपीलीय अधिकरण न्यायपीठ, मुंबई । IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, HON'BLE

M/S. Swarn Sagar Jewellers Pvt Ltd, Mumbai vs. ITO Ward 15(3)(4), Mumbai

In the result, appeal of the assessee is allowed

ITA 4864/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Oct 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri V.D. Parmar, AdvFor Respondent: Ms. Kavita Kaushik, Sr. D/R

Section 68

आदेश/O R D E R PER NARENDRA KUMAR BILLAIYA, AM: This appeal by the assesse is preferred against the order dated 11/04/2025 by NFAC, Delhi [hereinafter “the ld. CIT(A)”] pertaining to AY 2017-18. 2. The sum and substance of the grievance of the assessee is that

M/S. Shree Renuka Sugars Limited (Successor in Interest of M/S. Monica Trading Private Limited), Mumbai vs. Deputy Commissioner of Income Tax Circle 7(1)(1), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 4506/MUM/2025[2012-13]Status: DisposedITAT Mumbai16 Oct 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarm/S. Shree Renuka Sugars V/S. Deputy Commissioner Of Limited बनाम Income Tax, Circle – (Successor In Interest Of M/S 7(1)(1), Aayakar Bhavan, Monica Trading Pvt. Ltd.),2Nd& M.K. Road, Mumbai – 3Rd Floor, Kanakshree Arcade, 400020, Maharashtra Jnmc Road, Nehru Nagar, Belagavi – 590 010, Karnataka स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcs1728B Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Shri K.K. Chythanya, Sr. Adv. & Tata Krishna, AdvFor Respondent: Shri Umashankar Prasad, (CIT-DR)

Section 144Section 147

being without valid Document Identification Number (DIN) in violation of Circular No. 19/2019 dated 14.08.2019, 2. The Order of the Learned CIT (A), NFAC is not justified in law and on facts and circumstances of the case. 3. The Order of the Learned CIT(A), NFAC being passed ... with the Appellant with effect from 01.04.2022 vide order of the NCLT, Bengaluru Bench dated 22.10.2024. 4. The Order of the Learned CIT(A), NFAC is invalid and bad in law being passed in violation of Rule 5(1)(ii)(a) & (b) of the Faceless Appeal Scheme

Hitesh Shashikant Jhaveri, Borivali West vs. Deputy Commissioner of Income Tax Circle 42(1)(1), Kautilya Bhavan

In the result, both the appeals of the assessee for A

ITA 4344/MUM/2025[2012-13]Status: DisposedITAT Mumbai16 Oct 2025AY 2012-13

Bench: Shri Pawan Singh & Smt.Renu Jauhri & Hitesh Shashikantjhaveri Vs. Deputy Commissioner Of A/304, Alanknanda Income Tax Circle 42(1)(1) Building, 51St Tps Road, C41-43, G Block Bkc, Near Veer Sawarkar Garden, Gilban Area, Bandra Kurla Borivali (West), Complex, Bandra(East), Mumbai-400092. Mumbai-400051. "थायी लेखा सं./जीआइआर सं./Pan/Gir No:Adepj1181A Appellant .. Respondent

For Appellant: Shri RaghunathSarangapaniFor Respondent: Shri Hemanshu Joshi- Sr. DR

Section 147Section 250Section 68Section 69C

nominal gain of only Rs. 1,301/-, thereby negating the allegation of accommodation entry or tax evasion. 6. That the learned CIT(A)-NFAC erred in law and on facts in confirming the additions made by the Assessing Officer without independently verifying theevidence furnished by the Appellant, and by placing ... without any independent inquiry, cross- verification, or corroborative evidence, and are therefore liable to be deleted in law. 8. That the learned CIT(A)-NFAC erred in upholding the denial of the Appellant's claim of carried forward business loss of Rs. 28,94,299/- despite no specific finding against

Hitesh Shashikant Jhaveri, Borivali West vs. Deputy Commissioner of Income Tax Circle 42(1)(1), Kautilya Bhavan

In the result, both the appeals of the assessee for A

ITA 4343/MUM/2025[2011-12]Status: DisposedITAT Mumbai16 Oct 2025AY 2011-12

For Appellant: Shri RaghunathSarangapaniFor Respondent: Shri Hemanshu Joshi- Sr. DR

Section 147Section 250Section 68Section 69C

Rishabh Instruments Limited, Mumbai vs. PCIT -3, Mumbai

In the result, appeal filed by the assessee is allowed

ITA 3358/MUM/2025[2020-21]Status: DisposedITAT Mumbai16 Oct 2025AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain & Shri Girish Agrawalrishabh Instruments Ltd Vs. Pcit – 3 F-31, Satpur Midc, Nashik Room No. 612, 6Th Nashik – 422007 Floor, Aayakar Bhavan, Mk Road Pan/Gir No. Aaacr2228Q (Applicant) (Respondent)

Section 135Section 142(1)Section 143(3)Section 250Section 263Section 37Section 80G

challenging the impugned order dt. 17.03.2025 passed under section 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre (NFAC) / CIT(A) for the assessment year 2020-21. 2. Both the grounds raised by the assessee are interrelated and interconnected and relates to challenging

Uttam Hari More, Thane vs. Income Tax Officer, National Faceless Assessment Center, Delhi

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

ITA 2336/MUM/2025[2016-17]Status: DisposedITAT Mumbai16 Oct 2025AY 2016-17

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Hemant Shetty, A/RFor Respondent: Ms. Kavitha Kaushik, Sr. D/R

Section 147

आदेश/O R D E R PER NARENDRA KUMAR BILLAIYA, AM: This appeal by the assesse is preferred against the order dated 10/01/2025 by NFAC, Delhi [hereinafter “the ld. CIT(A)”] pertaining to AY 2016-17. 2. The sum and substance of the grievance of the assessee is that

Income Tax Officer, Ward 3(1), Kalyan vs. Vitthal Rukmini Sahakari Patpedthi, Kalyan

In the result, appeal of the assessee is allowed and appeal of the revenue is dismissed

ITA 2307/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Oct 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Sushant Alme, A/RFor Respondent: Ms. Kavitha Kaushik, Sr. D/R

Section 194A(3)(v)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

BILLAIYA, AM: I.T.A. No. 1570/Mum/2025 & ITA No. 2307/Mum/2025 are cross-appeals by the assessee and the revenue preferred against the order dated 10/01/2025 by NFAC, Delhi [hereinafter ‘the ld. CIT(A)’] pertaining to AY 2017-18. 2. Both the appeals were heard together and are disposed off by this common ... claim of deduction u/s 80P(2)(a)(i) of the Income Tax Act, 1961. However, the Ld. Assessing Officer and National Faceless Appeal Centre (NFAC) has erred in observing that the Co-operative Credit Societies are Co-operative Bank and thus covered u/s 80P(4) of the Income

Vitthal Rukmini Sahakari Patpedhi Ltd, Kalyan vs. DCIT Circle 3 Kalyan, Kalyan

In the result, appeal of the assessee is allowed and appeal of the revenue is dismissed

ITA 1570/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Oct 2025AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Sushant Alme, A/RFor Respondent: Ms. Kavitha Kaushik, Sr. D/R

Section 194A(3)(v)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(4)

ITO 13(2)(1), Mumbai vs. Sumangal Commodities Pvt. Ltd, Mumbai

ITA 1302/MUM/2025[2011]Status: DisposedITAT Mumbai16 Oct 2025

Bench: Justice (Retd.) C.V. Bhadang & Shri Prabhash Shankar: A.Y. : 2010-11

For Appellant: Shri Swapnil ChoudharyFor Respondent: Shri Rahul Hakani

Section 132(4)Section 148Section 68

JUSTICE (RETD.) C.V. BHADANG, PRESIDENT : By this appeal Revenue is challenging the order dated 26.02.2024 passed by the National Faceless Appeal Centre (NFAC) (‘CIT(A)’ for short) thereby deleting the addition of Rs. 1,30,90,000/- made by the Assessing Officer (‘AO’ for short) under Section

Michael Page International Recruitment Pvt Ltd, Mumbai vs. DCIT Circle 14(1)(1), Mumbai

ITA 6748/MUM/2024[2021-22]Status: DisposedITAT Mumbai16 Oct 2025AY 2021-22

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 153Section 37Section 41Section 92D

IN THE INCOME TAX APPELLATE TRIBUNAL “J” BENCH, MUMBAI SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER ITA

Firoz Alam, Saharanpur vs. ITO Ward-3(3)(3), Saharanpur

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

ITA 346/DEL/2025[2018-19]Status: DisposedITAT Delhi16 Oct 2025AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalfiroz Alam, Income Tax Officer, Quila Nawab Ganj, Ward-3(3), Saharanapur. Chakrata Road, Vs. Saharanpur, Uttar Pradesh-247001. Pan-Afspa9199P (Appellant) (Respondent) Assessee By None Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 23/07/2025 Date Of Pronouncement 23/07/2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A), In Short] Dated 28.08.2024 In Appeal No. Nfac/2017-18/10273096 Arising Out Of Order Passed U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (Hereinafter Referred As ‘The Act’) Dated 28.02.2023 For Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessment Was Reopened On The Basis Of The Information That Assessee Has Made Transaction Of Rs. 94,76, 190/- With A Company Who Was Indulged In Purchases & Sales Only On Papers Without Actual Moment Of Goods. Accordingly, The Order U/S 148A(D) Of The Act Was Passed & Notice U/S 148 Was Issued After Obtaining The Approval From The Competent Authorities. During The Firoz Alam Vs. Ito Course Of Reassessment Proceedings, The Assessee Never Appeared Nor Filed Any Reply Before The Ao And, Therefore, The Ao Proceed To Complete The Assessment Exparte By Making The Addition Of Rs.94,76,190/- As Unexplained Expenditure U/S 69C Of The Act Towards The Purchases Made From Two Parties.

Section 147Section 148Section 148ASection 221(1)Section 69C

AGARWAL, AM: This appeal is filed by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A), in short] dated 28.08.2024 in Appeal No. NFAC/2017-18/10273096 arising out of order passed u/s 147 r.w.s. 144 of the Income

Dd Global Capital Private Limited, Chandigarh vs. Income Tax Officer, Delhi

Appeal is allowed for statistical purposes

ITA 2684/DEL/2025[2017-18]Status: DisposedITAT Delhi16 Oct 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. T. N. Singla, CAFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR

Section 143(3)Section 250(6)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member & Sh. Manish

Earth Buildtech Private Limited, Delhi vs. The ACIT, Central Circle-25, New Delhi, Delhi

Appeal is allowed for statistical purposes

ITA 2678/DEL/2025[2017-18]Status: DisposedITAT Delhi16 Oct 2025AY 2017-18

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: NoneFor Respondent: Sh. Rajesh Kumar Dhanesta, Sr. DR

Section 147Section 250(6)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member & Sh. Manish