“Chief Commissioner”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(15A) / Section 1172,876 judgments

The decision most relied on for Chief Commissioner is Pvt Ltd. v. ACIT (93 Taxmann.com 296), cited in 98 judgments on BharatTax.

Leading authorities on Chief Commissioner

Pvt Ltd. v. ACIT

93 Taxmann.com 296 · 2018 · High Court

citing judgments

Approval granted by the Principal Chief Commissioner or Principal Commissioner under Section 151 for reassessment proceedings under Section 148 must reflect due application of mind. A mere endorsement of "approved" without reasons or reference to material is insufficient, as the approval serves as a safeguard and must be meaningful, not ritualistic or formal.

Financial Services Pvt. Ltd. v. Dy. CIT

457 ITR 647 · 2023 · High Court

citing judgments

The amended Section 151 of the Income-tax Act, governing the sanction for reassessment proceedings under Sections 148 and 148A, applies to cases initiated under the new reassessment regime. The specified authority for granting such sanction becomes the Principal Chief Commissioner or Principal Director General if more than three years have elapsed from the end of the relevant assessment year.

Ghanshyam K. Khabrani v. ACIT

346 ITR 443 · 2012 · High Court

citing judgments

The reassessment proceedings are invalid if the required sanction under Section 151 of the Income Tax Act is not obtained from the statutorily designated authority or if the approval is granted mechanically without due satisfaction. Approval by a higher authority cannot substitute the satisfaction of the authority specified in Section 151.

Mohinder Singh Gill v. Chief Election Commissioner

1 SCC 405 · 1978 · Supreme Court

citing judgments

When a statutory authority issues an order based on specific grounds, its validity must be assessed solely by those stated grounds and cannot be supported or improved by additional reasons provided later in affidavits or other means. An order that is invalid at its inception cannot be validated by subsequent justifications.

Sahara India v. CIT & Others

216 CTR 303 · 2008 · Reported

citing judgments

The requirement of prior approval from the Chief Commissioner or Commissioner under Section 142(2A) is a crucial safeguard against arbitrary assessment, placing a significant responsibility on the approving authority to ensure its genuine application and prevent it from becoming a mere formality.

New Noble Educational Society v. Chief Commissioner of Income Tax

448 ITR 594 · 2022 · Supreme Court

citing judgments

An institution qualifies as an 'educational institution' for tax exemption, including under Section 10(23C)(iiiab), only if it imparts structured, formal education, distinguishing it from general public utility activities under Section 2(15).

Star India Private Limited v. Chief Commissioner of Central Excise

280 ITR 321 · 2006 · Supreme Court

citing judgments

The Supreme Court holds that while the Legislature can enact laws retrospectively, this power does not normally extend to creating an offence or penal liability retroactively, nor to withdrawing a benefit already granted under a statute through retrospective amendment.

Oxford Academy for Career Development v. Chief CIT

315 ITR 382 · 2009 · High Court

citing judgments

The Commissioner of Income Tax (CIT) has no power to cancel registration granted under Section 12A of the Income Tax Act retrospectively, especially when there is no express provision in the Act for such cancellation and the order is quasi-judicial in nature.

Judgments citing Chief Commissioner

ACIT(It)-1(2)(1), Mumbai vs. Barclays Execution Services Limited, London

In the result, the appeal filed by the Revenue is dismissed and the cross-objection filed by the assessee is dismissed as infructuous

ITA 4253/MUM/2025[2017]Status: DisposedITAT Mumbai31 Oct 2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 144CSection 147Section 148Section 148ASection 151

alia, challenging the decision of the CIT(A) in holding that approval for issue of notice under section 148 was required from the Principal Chief Commissioner in terms of section 151(ii), and not merely from the Commissioner. The grievance essentially revolves around the interpretation and temporal applicability ... time of issuance of notice under section 148, the approval ought to have been obtained from the Principal Chief Commissioner of Income Tax. Accordingly, the CIT(A) quashed the re-assessment order as void ab initio, rendering the grounds on merits academic. 4 Barclays Execution Services Limited “Thus

Sukhad Jeevan Sansthan, Chittorgarh vs. CIT (Exemption) Jaipur, Jaipur

In the result, the appeal of the assessee is dismissed

ITA 447/JODH/2024[2023-24]Status: DisposedITAT Jodhpur30 Oct 2025AY 2023-24

Bench: Shri Laliet Kumar, Hon'Ble & Dr. Mitha Lal Meena, Hon'Ble

Section 10Section 11Section 12Section 80GSection 80G(5)

here concemed whether in the absence of any statutory provision to condone the delay in presenting the application under section 10(23C)(vi), the Chief Commissioner of Income-tax can exercise any such power". 7. The adjudicating authorities under the Income-tax Act are quasi judicial authorities. They can grant

Dy. Commissioner of Income Tax, Jaipur vs. Hem Chand Jain, Jaipur

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

ITA 670/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Rajesh Ojha, Ld. CIT &

Section 147Section 148Section 148ASection 151Section 250

Commissioner or Director, if three years or less than three years have elapsed from the end of the relevant assessment year; (ii) Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General, if more than three ... Where revenue issued notice u/s 148 to assessee after lapse of more than three years from end of relevant AY after obtaining approval from Chief Commissioner, since Chief Commissioner was not a specified authority under clause (ii) of section 151, reassessment proceedings were liable to be quashed. Ajay Duggal

Gajiben Mahotji Thakor, Ahmedabad vs. The Income Tax Officer, Ward-3(3)(8), Ahmedabad

In the result, appeal filed by the assessee is dismissed

ITA 324/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2011-12

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri Ketan Shah, Advocate & ShriFor Respondent: Shri Abhijit, Sr.DR

Section 143(2)Section 147Section 148Section 151Section 250Section 45

this effect are reproduced hereunder for clarity: “Power to transfer cases. 127. (1) The Principal Director General or Director General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner may, after giving the assessee a reasonable opportunity of being heard in the matter, wherever it is possible ... subordinate to the same Principal Director General or Director ITA No. 324/Ahd/2023 [Gajiben Mahotji Thakor vs. ITO] A.Y. 2011-12 - 8 – General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,— (a) where the Principal Directors General or Directors General or Principal Chief Commissioners or Chief Commissioners

Amit Suresh Agrawal, Satara vs. ITO Ward-2, Satara

In the result, appeal of the assessee is partly allowed

ITA 2225/PUN/2025[2016-17]Status: DisposedITAT Pune30 Oct 2025AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2225/Pun/2025 निर्धारण वषा / Assessment Year: 2016-17 Amit Suresh Agrawal, V The Income Tax Officer, Amit Trading Co, Plot No.35, S Ward-2, Satara. Satara – 415002. Maharashtra. Pan: Abgpa2925D Appellant/ Assessee Respondent / Revenue Assessee By Shri Suhas Kulkarni – Advocate Revenue By Shri Eknath Abhang – Add.Cit(Dr) Date Of Hearing 30/10/2025 Date Of Pronouncement 30/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This 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.2016-17 Dated 02.04.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 Dated 10.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

Section 147Section 148Section 149(1)(b)Section 151Section 151ASection 153ASection 153CSection 250Section 271(1)(c)Section 68

Commissioner or Director, if three years or less than three years have elapsed from the end of the relevant assessment year; (ii) Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General, if more than three ... Assessment Years have been elapsed, as per Section 151 of the Act, the order should have been approved by Principal Chief Commissioner of Income Tax(Pr.CCIT). Therefore, the order u/s.148A(d) is bad in law. 7.1 The Hon’ble Jurisdictional High Court in the case of Holiday Developers Private Limited

Hukam Chand Singla, Panipat vs. Income Tax Officer, Ward -1, Panipat

Appeal is allowed

ITA 6171/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Oct 2025AY 2018-19

Bench: Sh. Satbeer Singh Godaraita No. 6171/Del/2025 : Asstt. Year : 2018-19 Hukam Chand Singla, Vs Income Tax Officer, House No. 33-A, Shanti Nagar, Ward-1, Model Town, Panipat, Panipat, Haryana-132103 Haryana-132103 (Appellant) (Respondent) Pan No. Bdqps7971C Assessee By: Sh. Suresh Gupta, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 30.10.2025 Date Of Pronouncement: 30.10.2025 Order

For Appellant: Sh. Suresh Gupta, CAFor Respondent: Sh. Manoj Kumar, Sr. DR

Section 147Section 148Section 151Section 151(1)

such a notice issued after a lapse of three years from the end of the relevant assessment year, to be approved by the Principal Chief Commissioner............, as the case may be. 4. Faced with this situation, the Revenue could hardly dispute that the learned PCIT’s sanction obtained herein comes

Deputy Commissioner of Income Tax, Delhi vs. Assure Jewels Pvt. Ltd, Delhi

In the result, appeal of the Revenue is dismissed

ITA 2063/DEL/2024[2015-16]Status: DisposedITAT Delhi30 Oct 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishraआ.अ.सं/.I.T.A No.2063/Del/2024 िनधा"रणवष"/Assessment Year:2015-16 बनाम Dcit, Assure Jewels Pvt. Ltd., Room No.266, 2Nd Floor, 186/124, 1St Floor, Ravi Market, Vs. Jhandewalan Extn., Dariba Kalan, Chandni Chowk, New Delhi. New Delhi. Pan No.Aakca1155H अपीलाथ" Appellant ""यथ"/Respondent

Section 147Section 148Section 151Section 151(1)

year from the end of the relevant assessment year as provided 3 under Section 151(1) of the Act, it is only the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner who could have accorded the approval and not the Joint Commissioner of income ... expired from the end of the relevant assessment year as provided under Section 151(1) of the Act, it is only the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner who could have accorded the approval and not the Joint Commissioner of Income Tax. On this ground

Atul Vrajlal Karia, Rajkot vs. Ac / Dc (Int.Txn), Rajkot

In the result, appeal filed by the assessee is allowed in above terms

ITA 133/RJT/2025[2012-13]Status: DisposedITAT Rajkot29 Oct 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.133/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2012-13 Atul Vrajlal Karia Ac/Dc (Int. Txn), बनाम C/O. D.S. Karia & Co. Ca, 203, Rajkot Cosmo Complex, Mahila College Vs. Chowk, Kalawad Road, Rajkot Pan : Adwpk6568J (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Kalpesh Doshi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

For Appellant: Shri Kalpesh Doshi, ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR

Section 127Section 147Section 148Section 151Section 153CSection 250Section 282Section 69

Assessing Officers to whom the case is to be transferred are not subordinate to the same Principal Director General or Director General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner, (a) where the Principal Directors General or Directors General or Principal Chiel Commissioners or Chief Commissioners ... Principal Commissioners or Commissioners to whom such Assessing Officers are subordinate are in agreement, then the Principal Director General or Director General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner from whose jurisdiction the case is to be transferred may, after giving the assessee a reasonable

Rupesh Tambi, Jaipur vs. Assistant Commissioner of Income Tax, Central Circle-2, Jaipur

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

ITA 1470/JPR/2024[2015-16]Status: DisposedITAT Jaipur29 Oct 2025AY 2015-16

For Appellant: Shri S. R. Sharma, CA &For Respondent: Shri Gautam Singh Choudhary, Addl. CIT

Section 1Section 132Section 133ASection 153ASection 271Section 271A

account or other documents maintained in the normal course relating to such previous year; or (A) Otherwise not been disclosed to the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner before the date of search; or (ii) Any income of the specified previous year represented, either wholly ... FINANCE & COMPANY AFFAIRS DEPARTMENT OF REVENUE, CENTRAL BOARD OF DIRECT TAXES Room No. 254/North Block, New Delhi, the 10th March, 2003 To All Chief Commissioners of Income Tax, (Cadre Contra) & All Directors General of Income Tax Inv. Subject: Confession of additional Income during the course of search & seizure and survey

Volark Leasing Ifsc Pvt. Ltd, Gujarat vs. ACIT/DCIT, Circle, Gandhinagar, Gujarat

In the result, the appeal of the assessee is allowed

ITA 357/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2023-24

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Shri Pancham Sethi, ARFor Respondent: Date of Hearing

Section 143Section 143(1)Section 234BSection 250Section 80Section 80JSection 80L

grant condonation for the delay in filing Form 10CCF. 4.6 The appellant has the option to approach the jurisdictional Commissioner of Income Tax, Chief Commissioner of Income Tax, or Principal Chief Commissioner of Income Tax for the condonation of the delay in filing Form 10CCF and to claim the benefits

Siddharth Raikumar Nahar, Pune vs. DCIT, Cir-5, Pune

In the result, the appeal filed by the assessee is allowed as per terms indicated above

ITA 2062/PUN/2025[2017-18]Status: DisposedITAT Pune29 Oct 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2062/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Bharat Andhale

Section 147Section 148Section 148ASection 151Section 69A

relevant assessment year and for cases where the notice have been issued after more than three years, approval has to be taken from Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. Since in the instant case reopening has been carried out after three 4 Siddharth ... Raikumar Nahar years but the approval has been taken from Principal Commissioner and not from Principal Chief Commissioner, therefore, the approval is invalid and renders the reopening proceeding as illegal and bad in law. 6. We further notice that similar issue came for adjudication before this Tribunal in the case

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4671/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 148

specified authority for the issue of notice states specified authority for the purposes of section 148 and section 148A will be Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General, if more than three years ... Commissioner or Director, if three years or less than three years have elapsed from the end of the relevant assessment year; (ii) Principal Chief Commissioner or Principal Director General or where there is no Principal Chief Commissioner or Principal Director General, Chief Commissioner or Director General, if more than three

DCIT, Circle - 10(1), New Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4670/DEL/2024[2015-16]Status: DisposedITAT Delhi29 Oct 2025AY 2015-16

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 148

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4669/DEL/2024[2011-12]Status: DisposedITAT Delhi29 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 148

Rakshit Estates Private Limited, Gurgaon vs. Income Tax Officer, Gurgaon

In the result, appeal of assessee is allowed

ITA 3615/DEL/2024[2017-18]Status: DisposedITAT Delhi29 Oct 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandrarakshit Estates Private Vs. Income Tax Officer, Hsiidc Limited. Building, Vanijya Nikunj, Plot No. 11, Basement, J 2.1, Udhyogvihar, Phase-V, Sector 83, Gurgaon, Haryana Gurgaon, Haryana Pan: Aagcr0135G Appellant Respondent Assessee By Sh. Ramesh Chander, Adv Revenue By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 24/09/2025 Date Of Pronouncement 29/10/2025

Section 131Section 143(2)Section 143(3)

sake of clarity sub-section (1) of Section 127 is culled out as under: “(1) The [Principal Director General or] Director General or [Principal Chief Commissioner or] Chief Commissioner or [Principal Commissioner or] commissioner may, after giving the assessee a reasonable opportunity of being heard in the matter, wherever ... provisions of section 127 of the Act as under: Power to transfer cases (1) The [Principal Director General or] Director General or [Principal Chief Commissioner or] Commissioner may, after giving the assessee a reasonable opportunity of being heard in the matter, wherever it is possible to do so, and after

Joint Commissioner of Income Tax (in Situ) Circle-I, Ludhiana vs. Kapil Thapar, Ludhiana

In the result, appeal of the Department is dismissed and Cross

ITA 246/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh28 Oct 2025AY 2016-17

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 148Section 153CSection 69A

issuance of notice under section 148 to bring that escaped income to tax. This order is passed with the prior approval of the Pr. Chief Commissioner of Income Tax, NWR, Ludhiana." 7.4 The assessee filed its return of income in response to notice u/s 148 on 22.04.2023 at the same

Jayshree Gopallalji Haveli Charitable Trust-Ujalvav, Bhavnagar vs. The CIT (Exemption), Ahmedabad

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

ITA 220/AHD/2025[NA]Status: DisposedITAT Ahmedabad28 Oct 2025

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.220/Ahd/2025 िनधा"रण वष" /Assessment Year : Na Jayshree Gopallalji Haveli The Cit (Exemption) बनाम/ Charitable Trust-Ujalvav Ahmedabad – 380 015 V/S. At Ujalvav, Umrala Bhavnagar – 364 290 "थायी लेखा सं./Pan: Aaetj 3303 P (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mohit Balani, Ar Revenue By : Shri Alpesh Parmar, Cit-Dr

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Alpesh Parmar, CIT-DR

Section 80GSection 80G(5)

approval under section 80G. The assessee also relied on the decision of the Hon’ble Andhra Pradesh High Court in Tirumala Tirupati Devasthanam v. Chief Commissioner of Income Tax [2001] 119 Taxman 251 (AP) to support its claim. The CIT (Exemptions), however, rejected the Jayshree Gopallalji Haveli Charitable Trust-Ujalvav

Triloknath Vatsalya Vatika, Gandhinagar vs. The Dy.CIT, CPC, Bangalore Present Jao- the ITO, Ward-1 (Exemption), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1092/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad28 Oct 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1092/Ahd/2025 िनधा"रण वष" /Assessment Year : 2017-18 Triloknath Vatsalya Vatika The Dy.Cit बनाम/ At Balva Cpc Bangalore. V/S. Nr. Tahuko Hotel Present Jao Kalol The Ito Ward-1(Exemption) Gandhinagar – 382 001 Ahmedabad-380 015 "थायी लेखा सं./Pan: Aants 5604 B (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Kushal Fofaria, Ar Revenue By : Shri R.P. Rastogi, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 15/10/2025 घोषणा की तारीख /Date Of Pronouncement: 28/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal By The Assessee Is Directed Against The Order Dated 10/03/2025 Passed By The Office Of The Commissioner Of Income Tax, Appeal Addl/Jcit(A)-Gwalior [Hereinafter Referred To As “Cit(A)”], U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”), For The Assessment Year (Ay) 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri Kushal Fofaria, ARFor Respondent: Shri R.P. Rastogi, CIT-DR

Section 11Section 119(2)Section 119(2)(b)Section 12ASection 12A(1)(b)Section 139(1)Section 143(1)Section 234ASection 250Section 44A

referred to CBDT Circular No. 16/2022 dated 19.07.2022, which authorizes condonation of delay in filing Form 10B up to three years by the Principal Chief Commissioner or Chief Commissioner of Income-tax under section 119(2)(b) of the Act, and observed that the assessee had not sought such condonation

Navnirman Infracon Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 689/KOL/2025[2011-12]Status: DisposedITAT Kolkata28 Oct 2025AY 2011-12

Bench: S/Shriand Rajesh Kumar & Sonjoy Sarma

For Appellant: Shri Manish Tiwari, FCAFor Respondent: Shri Sandeep Kumar Mehta, Addl. Sr. DR

Section 148Section 250Section 56(2)(via)Section 56(2)(viia)

ITA No.689/Kol/2025 Assessment Year: 2011-12 IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA 'C' BENCH, KOLKATA BEFORE S/SHRIAND RAJESH KUMAR

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Vivek Gupta, Kolkata

The appeal of the revenue is dismissed

ITA 1557/KOL/2025[2013-14]Status: DisposedITAT Kolkata28 Oct 2025AY 2013-14

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 131Section 133ASection 143(3)Section 195Section 250Section 40Section 68

time of search/survey should be considered adversely. 18. The said CBDT Letter No.286/2/2003-IT(Inv) dated Oct 3, 2003 read as under: “To The Chief Commissioners of Income Tax, (Cadre Contra) & All Directors General of Income Tax Inv. Sir, Subject: Confession of additional Income during the course of search & seizure