“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

Dadar Avanti Co-Operative Housing Society Limited, Dadar Mumbai vs. Income Tax ITO Ward 22(1)(6), Mumbai

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

ITA 3429/MUM/2025[2013-2014]Status: DisposedITAT Mumbai22 Sept 2025AY 2013-2014

Bench: Shri Sandeep Gosain

Section 250Section 80PSection 80P(2)(a)Section 80P(2)(d)

challenging the impugned order dt. 25.03.2025 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 2013-14. The assessee has raised the following grounds of appeal: 1. In the facts and circumstances

Income Tax Officer 22(3)(6), Mumbai vs. Sachin Durgesh Chheda, Mumbai

In the result appeal filed by the revenue stands

ITA 3376/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Sept 2025AY 2018-19

Bench: Shri Sandeep Gosain

Section 139(1)Section 250Section 68

challenging the impugned order dt. 18.03.2025 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 2018-19. 2. All the grounds raised by the revenue are interrelated and interconnected and relates to challenging

Mahakali Ayyappa Seva Sangh, Mumbai vs. ITO Exem. Ward 2(1), Mumbai

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

ITA 3297/MUM/2025[2018-19]Status: DisposedITAT Mumbai22 Sept 2025AY 2018-19

Bench: Shri Sandeep Gosain

Section 250

challenging the impugned order dt. 21.04.2025 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 2018-19. From the records I noticed that appeal of the 2. assessee was dismissed

Rp Panchal HUF, Mumbai vs. Income Tax Officer, Ward-31(3)(2), Mumbai

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

ITA 2452/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Sept 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 143(3)Section 250

challenging the impugned order dt. 16.01.2025 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 2014-15. At the very outset, we noticed that there is delay of 2. 404 days in filing present

Nayan Builders and Developers Private Limited, Mumbai vs. ITO WD 7(2)(3), Mumbai

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

ITA 2322/MUM/2025[2003-2004]Status: DisposedITAT Mumbai22 Sept 2025AY 2003-2004

Bench: Hon’Ble Shri Sandeep Gosain

Section 250

impugned order dt. 25.02.2025 & 11.03.2025 passed u/s 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre, Delhi (NFAC) for the assessment years 2003-04 & 2010-11. 2. Since all the issues involved in these two appeals are common and identical, therefore, they have been

Nayan Builders and Developers Private Limited, Mumbai vs. ITO WD 7(2)(3), Mumbai

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

ITA 2310/MUM/2025[2010-2011]Status: DisposedITAT Mumbai22 Sept 2025AY 2010-2011

Bench: Hon’Ble Shri Sandeep Gosain

Section 250

Deluxe Recycling India Private Limited, Mumbai vs. Circle 4(1)(1), Mumbai

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

ITA 2046/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Sept 2025AY 2020-21

Bench: Shri Sandeep Gosain & Shri Girish Agrawalassessment Year: 2020-21 Assistant Commissioner Of Deluxe Recycling India Income Tax-4(1)(1), Private Limited Mumbai 13 17 Dady Sheth Agiary Vs. Lane, Kalbadevi Road, Kalbadevi, Mumbai-400002 (Pan: Aaacd8909N) (Appellant) (Respondent) Assessment Year: 2020-21 Deluxe Recycling India Private Assistant Commissioner Of Limited Income Tax-4(1)(1), 13 17 Dady Sheth Agiary Lane, Mumbai Vs. Kalbadevi Road, Kalbadevi, Mumbai-400002 (Pan: Aaacd8909N) (Appellant) (Respondent)

For Appellant: Shri Rahul Hakani, AdvocateFor Respondent: Shri Annavaram Kosuri, Sr. DR

Section 143(3)Section 32Section 40A(2)(b)Section 56Section 56(2)(x)

GIRISH AGRAWAL, ACCOUNTANT MEMBER: These two appeals filed by Revenue and assessee are against the order of ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi, vide order no. ITBA/NFAC/S/250/2024-25/1072735549(1), dated 30/01/2025 passed against the assessment order by MUM-C-(441)(1), u/s. 143(3) of the Income

Assistant Commissioner of Income Tax-4(1)(1), Mumbai vs. Deluxe Recycling India Private Limited, Mumbai

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

ITA 1969/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Sept 2025AY 2020-21

For Appellant: Shri Rahul Hakani, AdvocateFor Respondent: Shri Annavaram Kosuri, Sr. DR

Section 143(3)Section 32Section 40A(2)(b)Section 56Section 56(2)(x)

Mr. Jatin Harish Sotta, Mumbai vs. Income Tax Officer Ward 26(1)(7), Mumbai

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

ITA 1916/MUM/2025[2012-13]Status: DisposedITAT Mumbai22 Sept 2025AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Mr. Jatin Harish Sotta, Ito Ward 26(1)(7), A-16, Ajanta Apartment, C-41 To C-43, G Block, Bkc, Murar Road, Mulund West, Vs. Bandra (East), Mumbai-400080. Mumbai-400051. Pan No. Aqfps 6009 N Appellant Respondent

For Appellant: Ms. Kavita Kaushik, Sr. DRFor Respondent: Mr. Nimesh Chothani, CA

Section 144Section 147Section 69A

Centre, Delhi [in short ‘the Ld. CIT(A)’] for assessment year 2012-13, raising following grounds: 1. The Learned Commissioner of Income Tax (Appeals) (NFAC) on the facts and in the circumstances of the case and in law erred in confirming the action of the assessing officer in passing ... Income Tax Act assessing total income at Rs.2,86,80,200 Mr. Jatin Harish Sotta 2. The Learned Commissioner of Income Tax (Appeals) (NFAC) The Learned Commissioner of Income Tax (Appeals) (NFAC) The Learned Commissioner of Income Tax (Appeals) (NFAC) on the facts and in the circumstanc on the facts

Vipendra Ravindra Mandal, Thane vs. Income Tax Officer- Ward 22(3)(6), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1819/MUM/2025[2016-2017]Status: DisposedITAT Mumbai22 Sept 2025AY 2016-2017

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 Vipendra Ravindra Mandal, Ito Ward 22(3)(6), 405, Orchid Wing-F Lodha Crown, Piramal Chamber, Taloja Bypass Road, Kohni B.O. Vs. Mumbai-400012. Khoni, Thane-421204. Pan No. Alepm 8472 H Appellant Respondent

For Appellant: Mr. V.P. KothariFor Respondent: Mr. Bhagirath Ramawat, Sr. DR

Section 148Section 148ASection 149(1)(A)Section 54

National Faceless Appeal Centre, Delhi [in short ‘the Ld. CIT(A)’] for assessment year 2016-17, raising following grounds: 1. The learned CIT(A) NFAC has erred in law and on facts in dismissing the Ground No.1 in respect of the limitation for issue of Notice u/s 148 as provided ... considering the interpretation of the law and judicial decisions relied by the appellant. Vipendra Ravindra Mandal Vipendra Ravindra Mandal 2. The learned CIT(A) NFAC has erred in law and on facts in 2. The learned CIT(A) NFAC has erred in law and on facts in 2. The learned

ITO 19.3.1, Mumbai vs. Salem Steel Industries, Mumbai

The appeal of the revenue is dismissed

ITA 1299/MUM/2025[2008-09]Status: DisposedITAT Mumbai22 Sept 2025AY 2008-09

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Swapnil Choudhary, CIT-DRFor Respondent: None

Section 250Section 37Section 68Section 69CSection 74

Padmavathy S, AM: This appeal by the Revenue is against the order of the Commissioner of Income Tax (Appeals) / National Faceless Appeal Centre (NFAC), Delhi [In short 'CIT(A)'] passed under section 250 of the Income Tax Act, 1961 (the Act) dated 06.12.2024 for Assessment Years

Amit Ramaswamy Kalyanaraman, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(2)(1), Mumbai

In the result the appeal filed by the assessee stands dismissed

ITA 1234/MUM/2025[2011-12]Status: DisposedITAT Mumbai22 Sept 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

Section 144Section 250

challenging the impugned order dt. 16.01.2025 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 2011-12. 2. None appeared on behalf of the assessee nor his representative when the case was called. Contra

Shree Sadguru Seneshwara Sewa Samithi, Mumbai vs. The Income Tax Officer, Exemption Ward 2(3), Mumbai

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

ITA 1009/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Sept 2025AY 2014-15

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

For Appellant: Shri Kumar Kale, A/R (virtually appeared)For Respondent: Shri Leyaqat Ali Aafaqui, Sr. D/R

Section 11Section 12ASection 144Section 148Section 250Section 68

NARENDRA KUMAR BILLAIYA, AM: This appeal by the assessee is preferred against the order of the ld. dated 10/07/2024 by NFAC, Delhi [hereinafter the ‘ld. CIT(A)’] pertaining to AY 2014-15. 2. The grievance of the assessee reads as under:- “Being aggrieved by the order dated 10.07.2024 passed

Rasiklal Lavchand Vora, Thane vs. ACIT - Central Circle 1, Thane

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

ITA 5983/MUM/2024[2013-14]Status: DisposedITAT Mumbai22 Sept 2025AY 2013-14

Bench: Shri Sandeep Gosain

Section 144Section 147Section 250Section 44ASection 69C

revenue challenging the impugned order dt. 13.03.2025 passed u/s 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre (NFAC) / CIT(A) for the assessment year 2010-11. 2. None appeared on behalf of the assessee when the case was called repeatedly, in spite

Rasiklal Vora, Thane vs. ACIT - Central Circle -1, Thane

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

ITA 5982/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 Sept 2025AY 2016-17

Bench: Shri Sandeep Gosain

Section 144Section 147Section 250Section 44ASection 69C

Rasiklal Vora, Thane vs. ACIT, Central 1, Thane

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

ITA 5981/MUM/2024[2015-16]Status: DisposedITAT Mumbai22 Sept 2025AY 2015-16

Bench: Shri Sandeep Gosain

Section 144Section 147Section 250Section 44ASection 69C

Shree Ghatkopar Sarvajanik Jivdaya Khatu, Mumbai vs. ITO Exem Ward 2(3), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 5551/MUM/2024[2017-18]Status: DisposedITAT Mumbai22 Sept 2025AY 2017-18

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2017-18 Shree Ghatkopar Sarvajanik Income Tax Officer, Exem Jivdaya Khatu Ward-2(3), Jivdaya Lane Agra Road, Mumbai Vs. Ghatkopar, Mumbai – 400086 (Pan: Aabts9826R) (Appellant) (Respondent)

For Appellant: Ms. Simran Dhawan, Advocate and Ravi Ganatra, CAFor Respondent: Shri Arun Kanti Datta, CIT DR

Section 11Section 11(2)Section 12ASection 143(3)

GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by assessee is against the order of Ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi, vide order no. ITBA/NFAC/S/250/2024-25/1068043238(1), dated 28.08.2024 passed against the assessment order by Income Tax Officer, Exem ward-2(3), Mumbai, u/s. 143(3) of the Income ... under: “1. On the facts and the circumstances of the appellant company's case and in law, the Ed. Commissioner of Income Tax (Appeals), NFAC has erred in not quashing the assessment order passed by the Assessing Officer u/s 143(3) of the Income

Bennett Coleman & Co Ltd, Mumbai vs. DCIT 1(1)(1), Mumbai

ITA 2169/MUM/2024[2017-18]Status: DisposedITAT Mumbai22 Sept 2025AY 2017-18

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

For Appellant: Shri Madhur Agarwal & Shri Kshitij Kasi, A/RsFor Respondent: Shri Satyaprakash R. Singh, CIT D/R

Section 115JSection 14A

22/09/2025 आदेश/ORDER PER NARENDRA KUMAR BILLAIYA, AM: This appeal by the assessee is preferred against the order of the ld. dated 27/03/2024 by NFAC, Delhi [hereinafter the 'ld. CIT(A)'] pertaining to AY 2017-18. 2. The grievance of the assessee reads as under:- “1. On the facts

ACIT, Cir 8(2)(1), Mumbai vs. Western India Garments Pvt. Ltd., Mumbai

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

ITA 4211/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Sept 2025AY 2014-15

Bench: Smt. Beena Pillai & Shri Girish Agrawalassessment Year: 2014-15 Pico Capital Private Limited Deputy Commissioner Of (Successor In Interest Of M/S Income Tax-8(3)(2), Western India Garments Private Mumbai Limited ) 22(1) Bombay Cotton Miis Vs. Compound, Dattaram Lad Path Kalachowky, Mumbai - 400033 (Pan: Aaacw2493G) (Appellant) (Respondent) Assessment Year: 2014-15 Deputy Commissioner Of Income Western India Garments Tax - 8(2)(1), Private Limited Mumbai 22(1) Bombay Cotton Miis Compound, Vs. Dattaram Lad Path Kalachowky, Mumbai - 400033 (Pan: Aaacw2493G) (Appellant) (Respondent) Present For: Assessee : Shri Dharan Gandhi, Advocate Revenue : Shri Arun Kanti Datta, Cit Dr Date Of Hearing : 03.07.2025 Date Of Pronouncement : 22.09.2025 O R D E R Pico Capital Pvt Ltd. & Western India Garments Pvt Ltd. Ay 2014-15 Per Girish Agrawal: These Two Appeals Filed By Assessee & Revenue Are Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2023-24/1056675304(1), Dated 29.09.2023 Passed Against The Assessment Order By Dcit, Circle - 8(3)(2), Mumbai, U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 13.12.2016 For Assessment Year 2014- 15. 2. Grounds Taken By The Assessee Are Reproduced As Under: 1. The Ld. Cit(A), Nfac Has Erred In Confirming The Disallowance Of Rs. 13,52,543/- Made U/S 14A R.W.R. 8D Of The Rules Over & Above The Disallowance Of Rs. 11,02,185/- Made By The Appellant. 2. The Assessment Order U/S 143(3) Of The Act, Dated 13.12.2016 Is Bad In Law As The Same Has Been Passed In The Name Of The Non-Existent Person. 3. The Ld. Ao, Has Erred In The Levying Interest Under Section 234B Of The Act. 4. The Ld. Ao Erred In Initiating Penalty Proceedings U/S 271(1)(C) Of The Act.

For Appellant: Shri Dharan Gandhi, AdvocateFor Respondent: Shri Arun Kanti Datta, CIT DR

Section 143(3)Section 14ASection 234BSection 271(1)(c)Section 36(1)(vii)

GIRISH AGRAWAL, ACCOUNTANT MEMBER: These two appeals filed by assessee and revenue are against the order of Ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi, vide order no. ITBA/NFAC/S/250/2023-24/1056675304(1), dated 29.09.2023 passed against the assessment order by DCIT, Circle - 8(3)(2), Mumbai ... dated 13.12.2016 for Assessment Year 2014- 15. 2. Grounds taken by the assessee are reproduced as under: 1. The Ld. CIT(A), NFAC has erred in confirming the disallowance of Rs. 13,52,543/- made u/s 14A r.w.r. 8D of the Rules over and above the disallowance

Pico Capital Private Limited (Successor in Interest of M/S Western India Garments Private Limited ), Mumbai vs. Deputy Commissioner of Income Tax-8(3)(2), Mumbai

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

ITA 4007/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Sept 2025AY 2014-15

For Appellant: Shri Dharan Gandhi, AdvocateFor Respondent: Shri Arun Kanti Datta, CIT DR

Section 143(3)Section 14ASection 234BSection 271(1)(c)Section 36(1)(vii)