“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

Pradyumna Kumar Lath, Jharsuguda vs. Assistant Commissioner of Income Tax, Circle, Rourkela

In the result, appeal of the assessee stands allowed

ITA 820/CTK/2025[2016-17]Status: DisposedITAT Cuttack25 Feb 2026AY 2016-17

Bench: Shri George Mathan & Shri Madhusudan Sawdiaआयकर अपील सं/Ita No.820/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2016-2017) Vs Acit, Circle Rourkela, Rourkela Pradyumna Kumar Lath, At-Dalki, Po: Jharsuguda, Dist: Jharsuguda-768201 Pan No. :Aaopl 7797 H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri P.K.Mishra, Advocate राजस्व की ओर से /Revenue By : Shri Sanjib Banerjee, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 25/02/2026 घोषणा की तारीख/Date Of Pronouncement : 25/02/2026

For Appellant: Shri P.K.Mishra, AdvocateFor Respondent: Shri Sanjib Banerjee, Sr. DR

Section 148Section 148ASection 151

invalid inasmuch as the sanction has been admittedly issued by the Principal Commissioner of Income Tax ("PCIT") and not by the Principal Chief Commissioner of Income Tax (PCCIT"). 2. Petitioner's request for a copy of the sanction has also been denied. Even in the affidavit in reply, the Department ... proceedings was granted by Commissioner after expiry of 3 years from end of relevant assessment year, said approval should have been granted by Principal Chief Commissioner, thus, impugned order passed under section 148A(d) of the Act and impugned notice issued under section 148 of the Act were

Sudha Doshi, Hyderabad vs. ITO - Ward 5(1), Hyderabad

ITA 1775/HYD/2025[2015-16]Status: DisposedITAT Hyderabad25 Feb 2026AY 2015-16

For Appellant: Shri S. VenkateshwarluFor Respondent: Shri K. Vamsi Krishna

Section 143(1)Section 143(3)Section 147Section 148Section 148ASection 151ASection 250(6)

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘SMC’ Bench, Hyderabad Before Shri Manjunatha G., Accountant

Sudarsanam Bhaskaran, Chennai vs. ITO, Ncw-10(3), Chennai

The appeal of the assessee is allowed

ITA 3657/CHNY/2025[2018-19]Status: DisposedITAT Chennai25 Feb 2026AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3657/Chny/2025 िनधा$रण वष$ /Assessment Year: 2018-19

For Appellant: Mr. S. Girish Kumar, AdvocateFor Respondent: Dr. M.D. Vijay Kumar, JCIT

Section 147Section 148Section 148ASection 151Section 250

years and therefore as per the provisions of Section 151 of the Act the AO should have obtained the approval from Principle Chief Commissioner of Income Tax (PCCIT). The Ld. AR further submitted that in the present case the AO has obtained approval from Principle Commissioner of Income Tax (PCIT ... 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

Jignasa Atulkumar Shah, Ahmedabad vs. The Pr.CIT-1, Ahmedabad

In the result, the appeal filed by the Assessee is allowed

ITA 1140/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2018-19

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 10(38)Section 147Section 148Section 69Section 69A

I.T.A No. 1140/Ahd/2025 A.Y. 2018-19 Page No 6 Jignasa Atulkumar Shah vs. PR.CIT “Revision of orders prejudicial to revenue 263: (1) The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner may call for and examine the record at any proceeding under this

G2K Trust, Trichy vs. ITO, Ward-2(1), Trichy

In the result, both the appeals filed by the assessee are dismissed

ITA 3114/CHNY/2025[2018-19]Status: DisposedITAT Chennai24 Feb 2026AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.3113 & 3114/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 & 2018-19 G2K Trust, Vs. The Income Tax Officer, No. 5, Abila Avenue, Santosh Garden, Ward 2(1), Kulumani Main Road, Woraiyur, Tiruchirappalli. Trichy 620 102. [Pan: Aactg4763G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. K. Abhirame, Advocate ""थ" की ओर से/Respondent By : Ms. T. Mythili, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.02.2026 घोषणा की तारीख /Date Of Pronouncement : 24.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Dated 04.07.2025 & 15.07.2025 Passed By The Addl/Jcit(A), Panaji For The Assessment Years 2017-18 & 2018-19 Respectively.

For Appellant: Ms. K. Abhirame, AdvocateFor Respondent: Ms. T. Mythili, JCIT

Section 143(1)

rejection of the petitioner's application under section 119(2)(b) is only on the ground that according to the Chief Commissioner's opinion the plea of omission by the auditor was not substantiated. This court has difficulty to understand what more plea or proof any assessee could have brought

G2K Trust, Trichy vs. ITO, Ward-2(1), Trichy

In the result, both the appeals filed by the assessee are dismissed

ITA 3113/CHNY/2025[2017-18]Status: DisposedITAT Chennai24 Feb 2026AY 2017-18

For Appellant: Ms. K. Abhirame, AdvocateFor Respondent: Ms. T. Mythili, JCIT

Section 143(1)

Shailesh Asalraj Jain, Mumbai vs. Principal Commissioner of Income Tax, Mumbai 20, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2559/MUM/2025[2018-2019]Status: DisposedITAT Mumbai24 Feb 2026AY 2018-2019

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2018-19

For Appellant: Mr. Devendra JainFor Respondent: 03/12/2025

Section 147Section 148ASection 263

obtained from the year, therefore, sanction ought to have been obtained from the year, therefore, sanction ought to have been obtained from the Principal Chief Commissioner of Income Principal Chief Commissioner of Income-tax (PCCIT) tax (PCCIT) or Chief Commissioner of Income ioner of Income-tax (CCIT) in terms ... years have elapsed from the end of the relevant assessment year; from the end of the relevant assessment year; Shailesh Asalraj Jain (ii) Principal Chief Commissioner or Principal Director General or (ii) Principal Chief Commissioner or Principal Director General or (ii) Principal Chief Commissioner or Principal Director General

Sumit H Bhagchandani, Ahmedabad vs. DCIT, Circle 3(1)(1), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 1984/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad23 Feb 2026AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Parin Shah, ARFor Respondent: Shri Yogesh Mishra, Sr. DR

Section 270ASection 54FSection 54F(1)Section 54F(4)

still be computed in accordance with the formula prescribed under the Act. Similarly, Bombay High Court in the case of Humayun Suleman Merchant vs. Chief Commissioner of Income-tax, Sumit H Bhagchandani vs. DCIT Asst. Year –2017-18 - 7– Mumbai [2016] 73 taxmann.com 2 (Bombay)/[2016] 242 Taxman 189 (Bombay

Priya Pahwa, Ludhiana vs. Income Tax Officer, Ludhiana

In the result, appeal of the assessee is allowed

ITA 1112/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh20 Feb 2026AY 2018-19

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita No. 1112/Chd/2025 "नधा"रण वष" / Assessment Year: 2018-19 Priya Pahwa, The Ito, 66-D, Model Town Extension, Vs Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Bmtpp8544G अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Ms. Rano Jain, Advocate & Ms. Mansi Jain, Advocate Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 12.02.2026 Date Of Pronouncement : 20.02.2026

For Appellant: Ms. Rano Jain, Advocate and Ms. Mansi Jain, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR

Section 148Section 148ASection 151

order passed u/s 148A(d) and thereafter notice issued u/s 148 is without jurisdiction because a prior approval ought to have been taken from Chief Commissioner whereas AO has taken this approval from the PCIT, hence, impugned re-assessment order is not sustainable. In support of her contention, she relied ... would show that if three years from the end of the assessment year is expired, then such approval is to be taken from the Chief Commissioner of Income Tax, whereas in the present case, such approval has been taken from the Pr. Commissioner of Income Tax. A.Y.2018-19 4 In support

M/S.Wellknown Polyesters Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 4(3)(1), Mumbai

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

ITA 8704/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 147Section 148Section 148ASection 151

approve the issuance of notice u/s 148 of the new regime, as per section 151 of the Act, would be the Principal Chief Commissioner of Income Tax or the Chief Commissioner of Income Tax. In support, he placed reliance on the decision of the Hon’ble Supreme Court ... after obtaining the approval of the Joint Commissioner; and (b) after four years but within six years after obtaining the approval of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner. 75. After 1 April 2021, the new regime has specified different authorities for granting sanctions under

ITO-23(3)(6).Mumbai, Mumbai vs. Rajeshwar Bullion Trading, Mumbai

In the result, the appeal is dismissed

ITA 6132/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Rajeshwar Bullion Trading Income Tax Officer 2Nd Floor, 61/63, Ward 23(3)(6) Har Narayan Building, Vs. Mumbai Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Assessee) : (Revenue) & Income Tax Officer M/S. Rajeshwar Bullion Trading Ward 23(3)(6) 2Nd Floor, 61/63, Mumbai Vs. Har Narayan Building, Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Revenue) : (Assessee) Appellant By : Shri Dhran Gandhi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 16.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: The Captioned Appeals, One By The Assessee & The Other By The Revenue Arise Out Of Two Separate Orders Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Very Same Assessment Year (A.Y. For Short) 2017-18. However, While Assessee’S Appeal Arises Out Of Original Assessment Proceeding, The Revenue’S Appeal Arises Out Of Reassessment Proceeding U/S. 147 Of The Act. M/S. Rajeshwar Bullion Trading 2. At The Outset, We Will Deal With Assessee’S Appeal, Being Ita No.5754/Mum/2025. In Ground Nos. 1 & 2, The Assessee Has Challenged The Decision Of Ld. First Appellate Authority In Remanding The Issue Back To The Assessing Officer (A.O. For Short) For De Novo Adjudication. Whereas, In Ground No. 3, The Assessee Has Challenged The Non-Adjudication Of The Ground Relating To The Applicability Of Section 115Bbe Of The Act. Since, The Issues Are Overlapping, We Will Deal With Them Concurrently.

For Appellant: Shri Dhran GandhiFor Respondent: Shri Annavaram Kosuri (Sr. AR)

Section 115BSection 147Section 68

assessment year. Therefore, the competent authority who could have granted approval /sanction in terms of section 151(ii) of the Act is the Principal Chief Commissioner of Income Tax (‘PCCIT’ for short) or Chief Commissioner of Income Tax (‘CCIT’ for short). Whereas, he submitted, the A.O. has obtained the approval/sanction ... Principal Commissioner, or Principal Director or Commissioner or Director; and (b) after three years after obtaining the prior approval of the Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General. M/s. Rajeshwar Bullion Trading 76. Grant of sanction by the appropriate authority is a precondition

Durga Vijaykumar Lakhani, Mumbai vs. Pr. CIT 27, Mumbai

In the result, the appeal is allowed

ITA 5787/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Feb 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardurga Vijakumar Lakhani Principal Cit-27 Plot No. 117, A-Lane Gokul, Mumbai Vs. Near Sagar Vihar, Sector-8, Vashi, Navi Mumbai-400 703 Pan/Gir No. Aazpl 4339 E (Appellant) : (Respondent) Appellant By : Ms. Ritika Agarwal, Adv. Respondent By : Shri Annavaran Kosuri (Sr. Dr) Date Of Hearing : 12.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: This Is An Appeal By The Assessee Against Order Dated 28.07.2025 Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi For The Assessment Year (A.Y. For Short) 2015-16. 2. At The Outset, Ld. Counsel Appearing For The Assessee Drew Our Attention To Ground Nos. 1 & 3 & Submitted That The Appeal Can Be Decided On The Limited Issue Of Lack Of Proper Sanction For Reopening Of Assessment. For Deciding This Issue, We May Discuss Few Relevant Facts.

For Appellant: Ms. Ritika Agarwal, AdvFor Respondent: Shri Annavaran Kosuri (Sr. DR)

Section 147Section 148Section 151Section 151(1)

expiry of four years from the end of the relevant assessment year, the appropriate authority who could have granted approval /sanction is the Principal Chief Commissioner of Income Tax (‘PCCIT’ for short) or Chief Commissioner of Income Tax (‘CCIT’ for short) or Principal Commissioner of Income Tax (PCIT for short

M/S. Rajeshwar Bullion Trading, Mumbai vs. Asst. CIT, Circle 23(3), Mumbai

In the result, the appeal is dismissed

ITA 5754/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

For Appellant: Shri Dhran GandhiFor Respondent: Shri Annavaram Kosuri (Sr. AR)

Section 115BSection 147Section 68

DCIT 2(3)(1), Mumbai vs. Tata Steel Ltd, Mumbai

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

ITA 3555/MUM/2016[2008-09]Status: DisposedITAT Mumbai20 Feb 2026AY 2008-09

For Appellant: Shri J.D. Mistri, Sr. Advocate and Ms. Jasmin Amalsadvala, AdvocateFor Respondent: Shri Ajay Chandra, CIT DR

Section 143(3)Section 144Section 147Section 148Section 151Section 36(1)(iii)Section 57

provisions of sub-section (1) of Section 144-C. (ii) The sanction under the proviso to sub-section (1) of Section 151 of the Chief Commissioner to the issue of the Notice under Section 148 had not been obtained. or (iii) The Ld AO did not have any "reason

Tata Steel Ltd, Mumbai vs. Asst CIT 2(3), Mumbai

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

ITA 3294/MUM/2016[2008-09]Status: DisposedITAT Mumbai20 Feb 2026AY 2008-09

For Appellant: Shri J.D. Mistri, Sr. Advocate and Ms. Jasmin Amalsadvala, AdvocateFor Respondent: Shri Ajay Chandra, CIT DR

Section 143(3)Section 144Section 147Section 148Section 151Section 36(1)(iii)Section 57

Sudhansu Ranjan Nayak, Bhubaneswar vs. Income Tax Officer Ward 5(1), Bhubaneswar

In the result, appeal of the assessee is allowed

ITA 754/CTK/2025[2018-19]Status: DisposedITAT Cuttack19 Feb 2026AY 2018-19

Bench: Shri George Mathan & Shri Madhusudan Sawdiaआयकर अपील सं/Ita No.754/Ctk/2025 ("नधा"रण वष" / Assessment Year : 2018-2019) Sudhansu Ranjan Nayak, Vs Ito Ward-5(1), Bhubaneswar At Plot No.176, District Center Chandrasekharpur, Bhubaneswar Odisha-751016 Pan No. : Ajmpn 2651 D (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri P.K.Mishra, Narahari Swain & Himansu Bhusan Jena, Advocates राज"व क" ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 19/02/2026 घोषणा क" तार"ख/Date Of Pronouncement : 19/02/2026

For Appellant: Shri P.K.Mishra, Narahari Swain &For Respondent: Shri Vijay Singh, Sr. DR

Section 147Section 148Section 148A

considers that it is a fit case for issuing notice under Section 148 of the Act, necessary approval shall be obtained from the concerned Chief Commissioner of Income Tax as was the requirement at the material time. 6. It was the submission that the liberty must be granted

Society for Advancement in Education, Mussoorie vs. ITO Exemption Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 220/DDN/2025[2011-12]Status: DisposedITAT Dehradun18 Feb 2026AY 2011-12

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

Assessing Officer, after the expiry of a period of four years from the end of the relevant assessment year, unless the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner is satisfied, on the reasons recorded by the Assessing Officer, that it is a fit case ... case for the issue of such notice. (3) For the purposes of sub-section (1) and sub-section (2), the Principal Chief Commissioner or the Chief Commissioner or the g Principal Commissioner or the Commissioner or the Joint Commissioner, as the case may be, being satisfied on the reasons recorded

Society for Advancement in Education, Mussoorie vs. ITO Exemption Word Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 219/DDN/2025[2010-11]Status: DisposedITAT Dehradun18 Feb 2026AY 2010-11

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

Society for Advancement in Education, Mussoorie vs. ITO Exemption Word Dehradun, Dehradun

In the result, appeals of the assessee are allowed

ITA 218/DDN/2025[2009-10]Status: DisposedITAT Dehradun18 Feb 2026AY 2009-10

Bench: Yogesh Kumar U.S. & Shri Sanjay Awasthi

Section 143Section 143(3)Section 147Section 148Section 151Section 158

Br Associates, Uttarakahand vs. ACIT, Rishikesh

In the result, the appeal of the assessee is allowed and the assessment order is quashed

ITA 175/DDN/2025[2016-17]Status: DisposedITAT Dehradun18 Feb 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2016-17] M/S. B R Associates Vs Acit Jolly Grant, Circle-1(4)(1) Bhaniyawala, Dehradun, Rishikesh, Uttarakhand-248140 Uttarakhand-249201 Pan-Aaqfb6241E Appellant Respondent Assessee By Shri Kanwal K.Juneja, Ca Revenue By Shri A.S.Rana, Sr.Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 08.07.2025 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Cit(A), Dehradun/10296/2018-19 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 28.12.2018 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2016-17. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed Its Return Of Income On 08.10.2016 Declaring Total Income At Inr 46,02,250/-. The Case Was Selected For Scrutiny Under Cass & The Notice Was Issued By Ito, Ward-1(2), Dehradun Thereafter, The Case Was Transferred To Dcit, Circle-1(1)(1), Dehradun. Thereafter, Various Notices Were Issued & Replies Were Filed By The Assessee. After Considering The Submissions, Total Income Was Assessed At Inr 1,93,96,755/- By Making Addition Of Inr 55.00 Lakhs Towards Bogus Advances & Inr 14,13,600/- As Deemed Income & Further Disallowance Of Expenses Of Inr 78,80,905/- Was Made.

Section 142(1)Section 143(2)Section 143(3)Section 250Section 43C

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