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“Commissioner (Appeals)”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(16A) / Section 1174,761 judgments

The decision most relied on for Commissioner (Appeals) is Jute Corporation of India Ltd. v. CIT (187 ITR 688), cited in 1,372 judgments on BharatTax.

Leading authorities on Commissioner (Appeals)

Jute Corporation of India Ltd. v. CIT
187 ITR 688 · 1991 · Supreme Court
1,372
citing judgments

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

CIT v. Premkumar Arjundas Luthra (HUF)
297 CTR 614 · 2017 · High Court
659
citing judgments

The Commissioner of Income-tax (Appeals) cannot dismiss an appeal for non-prosecution or default in appearance. Under Section 250(6) of the Income-tax Act, the CIT(A) must decide the appeal on its merits, even in an ex parte proceeding.

Ahmedabad Electricity Co. Ltd. v. CIT
199 ITR 351 · 1993 · High Court
441
citing judgments

Appellate authorities can consider additional grounds for deduction, even if not originally claimed before the Assessing Officer or Appellate Assistant Commissioner, provided the facts are not disputed and it pertains to a legal claim for correct tax liability. This is because the purpose of an appeal is to ascertain the correct tax liability.

CIT v. Kanpur Coal Syndicate
53 ITR 225 · 1964 · Supreme Court
359
citing judgments

The Commissioner (Appeals) holds plenary powers when disposing of an appeal, with their scope being coterminous with the Assessing Officer. This allows the CIT(A) to exercise all powers of the AO, including admitting additional evidence and redetermining income.

CIT v. Shapoorji Pallonji Mistry
44 ITR 891 · 1962 · Supreme Court
278
citing judgments

The Commissioner of Income-tax (Appeals) cannot enhance an assessment by introducing a new source of income or by changing the head of income during appellate proceedings.

Commissioner of Income Tax Madras v. Chenniyappa Mudiliar
1 SCC 591 · 1985 · Reported
225
citing judgments

The appellate tribunal must render a proper decision on both facts and law, disposing of an appeal on its merits rather than dismissing it solely due to the appellant's absence. This obligation is derived from Section 33(4) of the Income Tax Act, 1922, and reflects principles of natural justice.

Mahindra and Mahindra Ltd. v. DCIT
30 SOT 374 · 2009 · ITAT
201
citing judgments

The Commissioner of Income Tax (Appeals) cannot expand the scope of an assessment or improve the Assessing Officer's case in a manner that usurps the revisional power of the Commissioner of Income Tax under Section 263 of the Income-tax Act.

CIT v. Jansampark Advertising & Marketing (P.) Ltd.
56 Taxmann.com 286 · 2015 · High Court
196
citing judgments

The Commissioner of Income-tax (Appeals) has an independent statutory obligation to conduct proper inquiries and verify facts, especially when the Assessing Officer has failed to do so. The CIT(A) must ensure effective inquiry is carried out before deleting additions or accepting additional evidence.

Judgments citing Commissioner (Appeals)

Anita Snehadeep Soni, Nagpur vs. ITO Ward 4(4), Nagpur

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

ITA 274/NAG/2024[2018-19]Status: DisposedITAT Nagpur12 Dec 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Smt. Veena AgrawalFor Respondent: Shri Abhay Y. Marathe
Section 147Section 69A

business woman, homemaker and all her financial transactions were managed by her husband. Her husband was unaware of the notices and order issued by Commissioner (appeals). When the recovery notice came at the permanent address of the appellant then he became aware of the demand. Therefore the appellant could

Chaitanya Narahari Bhosale, Sindhudurg vs. Income Tax Officer, Kudal

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

ITA 1510/PUN/2024[AY 2013-14]Status: DisposedITAT Pune11 Dec 2024

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2013-14

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Ramnath P Murkunde
Section 142(1)Section 144Section 147Section 148Section 2Section 250(6)Section 68

NFAC has not followed the mandatory requirement of the provisions of section 250(6) of the Act, according to which, the order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision

Kerala State Co-Operative Bank Ltd, Thiruvananthapuram vs. DCIT, Circle-1(1), Thiruvananhapuram

ITA 171/COCH/2024[2018-2019]Status: DisposedITAT Cochin11 Dec 2024AY 2018-2019

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: Shri Dijo Mathew, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(2)Section 270ASection 270A(1)Section 270A(2)Section 36(1)(viia)Section 40

which the respective penalties can be imposed. “Penalty for under-reporting and misreporting of income. 270A. (1) The Assessing Officer or 95[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that any person ... following, namely:— (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or 96[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Commissioner or the Principal Commissioner, as the case may be, is satisfied that the explanation is bona fide

Kag India Private Limited, Chennai vs. PCIT Central Circle -2, Chennai

In the result the appeal of the assessee is allowed

ITA 1366/CHNY/2024[2020-21]Status: DisposedITAT Chennai11 Dec 2024AY 2020-21

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1366/Chny/2024 िनधा"रणवष" / Assessment Year: 2020-21 The Pcit (Central), M/S. Kag India Pvt Ltd., V. Chennai -2. No. 264/15-1, Sathiyanathan Complex, Velachery Road, East Tambaram, Chennai – 600 059. [Pan: Aadck-5381-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. Y. Sridhar, Fca ""यथ"क"ओरसे/Respondent By : Shri. Nilay Baran Som, Cit सुनवाई क" तार"ख/Date Of Hearing : 21.11.2024 घोषणा क" तार"ख/Date Of Pronouncement : 11.12.2024 आदेश /O R D E R

For Appellant: Shri. Y. Sridhar, FCAFor Respondent: Shri. Nilay Baran Som, CIT
Section 132Section 139Section 153ASection 263Section 270ASection 270A(9)(e)Section 271(1)

section 270A of the Act, which reads as under: 270A. Penalty for under-reporting and misreporting of income. (1)The Assessing Officer or the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that any person who has under-reported ... include the following, namely:— (a)the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or the Commissioner (Appeals) or the Commissioner or the Principal Commissioner, as the case may be, is satisfied that the explanation is bona fide and the assessee

Global Institute of Technology Society, Jaipur vs. DCIT-Circle-Exemption, Jaipur

In the result the appeal of the revenue in ITA no

ITA 296/JPR/2024[2017-18]Status: DisposedITAT Jaipur11 Dec 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri S.L. Poddar, AdvocateFor Respondent: Shri Anup Singh, Addl. CIT-DR
Section 11Section 13(1)(c)Section 13(3)

provisions of Sec.251(2) are quoted below :- 17 GLOBAL INSTITUTE OF TECHNOLOGY SOCIETY, JAIPUR VS DCIT-CIRCLE (EXEMPTION), JAIPUR Powers of the [Joint Commissioner (Appeals) or the] Commissioner (Appeals). 251. (1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers- (a) in an appeal against ... reduce the penalty; (c) in any other case, he may pass such orders in the appeal as he thinks fit. (2) The [Joint Commissioner (Appeals) or the] Commissioner (Appeals) [ as the case may be,] shall not enhance an assessment or a penalty or reduce the amount of refund unless

Bansal Foundation, Kolkata vs. I.T.O., Ward - 1(2), Exemption, Kolkata

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

ITA 107/KOL/2023[2018-2019]Status: DisposedITAT Kolkata10 Dec 2024AY 2018-2019

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 107/Kol/2023 Assessment Year: 2018-2019 Bansal Foundation,………………………………Appellant 119, Park Street, 3Rd Floor, Kolkata-700016 [Pan:Aadtb0630J] -Vs.- Income Tax Officer,……………………………...Respondent Ward-1(2), Exemption, Kolkata, 10B, Middleton Row, Kolkata-700071 Appearances By: Ms. Puja Somani, Advocate, Appeared On Behalf Of The Assessee Shri Nicholash Murmu, Addl. Cit, D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: November 13, 2024 Date Of Pronouncing The Order: December 10, 2024 O R D E R

Section 1Section 11Section 12ASection 143(1)

Appeals). 3. The assessee did not appear before the ld. CIT(Appeals) inspite of repeated notices issued by him. Thereafter the ld. Commissioner (Appeals) had no other option except passing the order on merits based on the material available on record. The ld. CIT(Appeals) confirmed the addition made

Preeti Chirania, Mumbai vs. The Income Tax Officer Ward - 28(2)(4), Navi Mumbai

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

ITA 4245/MUM/2024[2012-13]Status: DisposedITAT Mumbai10 Dec 2024AY 2012-13

Bench: Shri Sandeep Gosain & Ms. Padmavathy Svs. Ito, Ward – 28(2)(4) Preeti Chirania 309, 3Rd Floor, Tower No. Flat No.3, 1St Floor, 6, Vashi Rly Stn., Mangesh Santa Durga Commercial Complex, Chs, Sector – 17, Nerul Vashi Navi Mumbai – 400 (E), Navi Mumbai – 400 703. 706. Pan/Gir No. Akbpc0636M (Applicant) (Respondent)

Section 148Section 234BSection 250Section 68

Court dismissed the Department's appeal saying that no question of law arose from the order of the Tribunal affirming the order of the Commissioner (Appeals) allowing relief to the assessee, and the findings of the Commissioner (Appeals) to the effect that there was no adverse comment from the stock ... Appellate Tribunal. After detailed discussion, the Income-tax Appellate Tribunal has recorded the following findings of fact The above findings recorded by the learned Commissioner (Appeals) are quite exhaustive whereby he has discussed the basis on which the Assessing Officer had made the additionsWhile allowing relief to the assessee

Robert Bosch Engineering and Business Solutions Private Limited, Bengaluru vs. The Joint Commissioner of Income Tax, Large Tax Payers Unit, Bangalore

In the result, the appeal of the Revenue is hereby dismissed

ITA 593/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing
Section 115Section 115JSection 237Section 80J

PCIT vs. Balmer Lawrie and Company Ltd reported in 149 taxmann.com 286 where in it was held as under: It is noted that the Commissioner (Appeals) has taken specific note of the fact that the expenses claimed by the assessee as prior period, the liability to pay had crystallized during ... year and therefore the claim was allowed. Further the Tribunal noted that no appeal was preferred by the revenue against the orders of the Commissioner (Appeals) for the assessment years 2007-08 to 2009-10 and the appeals filed by the revenue for the assessment years

Deputy Commissioner of Income Tax, Circle- 2, Ltu, Bengaluru vs. M/S. Robert Bosch Engineering and Business Solutions Private Limited, Bangalore

In the result, the appeal of the Revenue is hereby dismissed

ITA 446/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing
Section 115Section 115JSection 237Section 80J

PCIT vs. Balmer Lawrie and Company Ltd reported in 149 taxmann.com 286 where in it was held as under: It is noted that the Commissioner (Appeals) has taken specific note of the fact that the expenses claimed by the assessee as prior period, the liability to pay had crystallized during ... year and therefore the claim was allowed. Further the Tribunal noted that no appeal was preferred by the revenue against the orders of the Commissioner (Appeals) for the assessment years 2007-08 to 2009-10 and the appeals filed by the revenue for the assessment years

Glaxosmithkline Pharmaceuticals Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle -7(1)(1), Mumbai

In the result, both the appeals filed by the assessee for A

ITA 3306/MUM/2024[2000-01]Status: DisposedITAT Mumbai09 Dec 2024AY 2000-01

Bench: Ms. Kavitha Rajagopal, Jm & Shri Girish Agrawal, Am

For Appellant: Shri Anish Thacker &For Respondent: Shri. Ram Krishn Kedia (Sr. DR.)
Section 143(1)Section 143(3)Section 154Section 244ASection 244A(2)Section 250

assessee. Mere fact that the claim came to be granted by the Appellate Commissioner, would not change this position. In essence, what the Commissioner (Appeals) did was to allow a claim which in law, in his opinion, was allowable by the Assessing Officer. In other words, by passing order ... South Indian Bank Ltd. [2012] 340 ITR 574 in which the assessee had raised a belated claim for deduction which was allowed by the Commissioner (Appeals). The Revenue, therefore, contended that for such delay, interest should be declined under Section 244A of the Act. In the said case also

Glaxosmithkline Pharmaceuticals Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle-7(1)(1), Mumbai

In the result, both the appeals filed by the assessee for A

ITA 3305/MUM/2024[1999-20]Status: DisposedITAT Mumbai09 Dec 2024AY 1999-20

Bench: Ms. Kavitha Rajagopal, Jm & Shri Girish Agrawal, Am

For Appellant: Shri Anish Thacker &For Respondent: Shri. Ram Krishn Kedia (Sr. DR.)
Section 143(1)Section 143(3)Section 154Section 244ASection 244A(2)Section 250

assessee. Mere fact that the claim came to be granted by the Appellate Commissioner, would not change this position. In essence, what the Commissioner (Appeals) did was to allow a claim which in law, in his opinion, was allowable by the Assessing Officer. In other words, by passing order ... South Indian Bank Ltd. [2012] 340 ITR 574 in which the assessee had raised a belated claim for deduction which was allowed by the Commissioner (Appeals). The Revenue, therefore, contended that for such delay, interest should be declined under Section 244A of the Act. In the said case also

Avr Storage Tank Terminals Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

In the result, the appeal is allowed for statistical purposes

ITA 1350/KOL/2024[2020-2021]Status: DisposedITAT Kolkata06 Dec 2024AY 2020-2021

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2020-21

For Appellant: Shri Dipran Mukherjee, ARFor Respondent: Shri P.P. Barman, Addl. CIT, Sr. DR
Section 115BSection 139(1)Section 143(3)Section 144BSection 234ASection 234BSection 234CSection 244ASection 250Section 32

reason for arriving at such decision. The provisions of section 250(6) are reproduced as under: “250(6) – The order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision ... taxmann.com 348 (Madras) it has been held that a speaking order on merits with reasons and findings is to be passed by Commissioner (Appeals) on basis of ground raised in assessee's appeal; he cannot dispose assessee's appeal merely by holding that Assessing Officer's order is a self

Dy. Commissioner of Income Tax, Central Circle, Meerut vs. Smt. Kamlesh, Delhi

Appeal is dismissed

ITA 2152/DEL/2024[2014-15]Status: DisposedITAT Delhi06 Dec 2024AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri M. Balaganeshassessment Year: 2014-15 Dcit, Vs. Smt. Kamlesh, Central Circle, 1402/1403, Vidhyanchal Meerut Tower, Kaushambi, Ghaziabad Pan :Akypk3905E (Appellant) (Respondent) Assessee By Sh. Rohit Agarwal, Ca Department By Ms. Jaya Choudhary, Cit(Dr)

Section 153ASection 56(2)(vi)Section 68

genuineness of persons wan had introduced share capital and on account of failure to prove capacity of loan creditors as well as genuineness transactions Commissioner (Appeals) found that shareholders were all private limited companies who had made investments out of their share capital and reserve through banking channels and assessee ... been able to show any perversity in aforesaid findings of fact by authorities below Whether therefore, Tribunal was right in confirming order passed by Commissioner (Appeals) and holding that no addition could be made under section 68- Held, yes (Paras 21, 23 and 24] [In favour of assessee

ACIT Central Circle, Ghaziabad vs. A1-Dua Food Processing Private Limited, New Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 1007/DEL/2023[2017-18]Status: DisposedITAT Delhi06 Dec 2024AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Sudhir Pareekacit, Central Circle, Vs. Al-Dua Food Processing Pvt. Ltd., Ghaziabad. 16, Fire Brigade Lane, Connaught Place, New Delhi – 110 001. (Pan : Aagca0396J) (Appellant) (Respondent) Assessee By : Shri Deepak Singh, Advocate Revenue By : Shri Javed Akhtar, Citdr Date Of Hearing : 25.09.2024 Date Of Order : 06.12.2024 O R D E R Per S. Rifaur Rahman,Am: 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-4, Kanpur [Hereinafter Referred To ‘Ld. Cit (A)’] Dated 25.01.2023 For Assessment Year 2017-18. 2. Brief Facts Of The Case Are, Assessee Filed Its Return Of Income Declaring Total Income Of Rs.8,76,98,220/- On 30.11.2017. The Return Was Processed U/S 143(1) Of The Income-Tax Act, 1961 (For Short ‘The Act’). The Case Was Selected For Scrutiny Under Cass & Statutory Notices

For Appellant: Shri Deepak Singh, AdvocateFor Respondent: Shri Javed Akhtar, CITDR
Section 143(1)Section 143(2)Section 145Section 40A(3)

pointed out any particular defect or discrepancy in the account books maintained by the assessee. During the course of hearing before the Commissioner (Appeals), it was pointed out by the assessee that her account books were duly audited under Section 44AB of the Central Excise Act and the quantitative details ... regards the marginal increase in the weight of the finished product, the explanation given by the assessee had been accepted not only by the Commissioner (Appeals) but also by the Tribunal. The Assessing Officer had no material before him on the basis of which it could be said that

DCIT Circle 27(1), New Delhi vs. United Drilling Tools Ltd., New Delhi

In the result, the Appeal filed by the Revenue is dismissed

ITA 5913/DEL/2019[2015-16]Status: DisposedITAT Delhi06 Dec 2024AY 2015-16

Bench: Before Shri Shamim Yahya & Shri Yogesh Kumar U.S.

Section 143(1)Section 143(2)Section 36(1)(va)

issue was raised was that Assessing Officer had held that no amount was actually paid on account of goodwill. However, the Commissioner (Appeals) has come to the conclusion from the orders of High Court ordering amalgamation that assets and liabilities of the amalgamated company were transferred to the assessee

Shantilal R. Patel, Panchmahal vs. The Income Tax Officer, Ward-1, Lunawada

In the result, all the four appeals filed by the assessee are partly allowed for the statistical purposes

ITA 1576/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2017-18

Bench: Ms. Suchitra Kambleआयकर अपील सं./Ita Nos. 1573, 1574, 1575 & 1576/Ahd/2024 िनधा"रण वष"/Asstt. Years: (2012-2013, 2013-14, 2016-17 & 2017-18) Shantilal R Patel, Income Tax Officer, 1, Shriji Park, बनाम Ward-1, Vs. Lunawada Vardhari Road, Lunawada. Lunawada, Panchmahal-389230. Pan: Akbpp6276G (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri Mk Patel, Ar Revenue By : Shri N J Vyas, Sr.Dr

For Appellant: Shri MK Patel, ARFor Respondent: Shri N J Vyas, Sr.DR
Section 234Section 234BSection 271(1)(c)Section 271ASection 69A

attended the hearing. 1.1 The appellant submits that similar additions made in appellant's own case have been fully deleted by the Commissioner (Appeals) for the Asst. Year 2012-13, 2014-15, 2015-16 and 2018-19. 2.0 The learned Commissioner of Income Tax (Appeals), NFAC erred ... attended the hearing. 1.1 The appellant submits that similar additions made in appellant's own case have been fully deleted by the Commissioner (Appeals) for the Asst. Year 2012-13, 2014-15, 2015-16 and 2018-19. 2.0 The learned Commissioner of Income Tax (Appeals), NFAC erred

Shantilal R. Patel, Panchmahal vs. The Income Tax Officer, Ward-1, Lunawada

In the result, all the four appeals filed by the assessee are partly allowed for the statistical purposes

ITA 1575/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2016-17

Bench: Ms. Suchitra Kambleआयकर अपील सं./Ita Nos. 1573, 1574, 1575 & 1576/Ahd/2024 िनधा"रण वष"/Asstt. Years: (2012-2013, 2013-14, 2016-17 & 2017-18) Shantilal R Patel, Income Tax Officer, 1, Shriji Park, बनाम Ward-1, Vs. Lunawada Vardhari Road, Lunawada. Lunawada, Panchmahal-389230. Pan: Akbpp6276G (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri Mk Patel, Ar Revenue By : Shri N J Vyas, Sr.Dr

For Appellant: Shri MK Patel, ARFor Respondent: Shri N J Vyas, Sr.DR
Section 234Section 234BSection 271(1)(c)Section 271ASection 69A

attended the hearing. 1.1 The appellant submits that similar additions made in appellant's own case have been fully deleted by the Commissioner (Appeals) for the Asst. Year 2012-13, 2014-15, 2015-16 and 2018-19. 2.0 The learned Commissioner of Income Tax (Appeals), NFAC erred ... attended the hearing. 1.1 The appellant submits that similar additions made in appellant's own case have been fully deleted by the Commissioner (Appeals) for the Asst. Year 2012-13, 2014-15, 2015-16 and 2018-19. 2.0 The learned Commissioner of Income Tax (Appeals), NFAC erred

Shantilal R. Patel, Panchmahal vs. The Income Tax Officer, Ward-1, Lunawada

In the result, all the four appeals filed by the assessee are partly allowed for the statistical purposes

ITA 1574/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2013-14

Bench: Ms. Suchitra Kambleआयकर अपील सं./Ita Nos. 1573, 1574, 1575 & 1576/Ahd/2024 िनधा"रण वष"/Asstt. Years: (2012-2013, 2013-14, 2016-17 & 2017-18) Shantilal R Patel, Income Tax Officer, 1, Shriji Park, बनाम Ward-1, Vs. Lunawada Vardhari Road, Lunawada. Lunawada, Panchmahal-389230. Pan: Akbpp6276G (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri Mk Patel, Ar Revenue By : Shri N J Vyas, Sr.Dr

For Appellant: Shri MK Patel, ARFor Respondent: Shri N J Vyas, Sr.DR
Section 234Section 234BSection 271(1)(c)Section 271ASection 69A

attended the hearing. 1.1 The appellant submits that similar additions made in appellant's own case have been fully deleted by the Commissioner (Appeals) for the Asst. Year 2012-13, 2014-15, 2015-16 and 2018-19. 2.0 The learned Commissioner of Income Tax (Appeals), NFAC erred ... attended the hearing. 1.1 The appellant submits that similar additions made in appellant's own case have been fully deleted by the Commissioner (Appeals) for the Asst. Year 2012-13, 2014-15, 2015-16 and 2018-19. 2.0 The learned Commissioner of Income Tax (Appeals), NFAC erred

Shantilal R. Patel, Panchmahal vs. The Income Tax Officer, Ward-1, Lunawada

In the result, all the four appeals filed by the assessee are partly allowed for the statistical purposes

ITA 1573/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2012-13

Bench: Ms. Suchitra Kambleआयकर अपील सं./Ita Nos. 1573, 1574, 1575 & 1576/Ahd/2024 िनधा"रण वष"/Asstt. Years: (2012-2013, 2013-14, 2016-17 & 2017-18) Shantilal R Patel, Income Tax Officer, 1, Shriji Park, बनाम Ward-1, Vs. Lunawada Vardhari Road, Lunawada. Lunawada, Panchmahal-389230. Pan: Akbpp6276G (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri Mk Patel, Ar Revenue By : Shri N J Vyas, Sr.Dr

For Appellant: Shri MK Patel, ARFor Respondent: Shri N J Vyas, Sr.DR
Section 234Section 234BSection 271(1)(c)Section 271ASection 69A

attended the hearing. 1.1 The appellant submits that similar additions made in appellant's own case have been fully deleted by the Commissioner (Appeals) for the Asst. Year 2012-13, 2014-15, 2015-16 and 2018-19. 2.0 The learned Commissioner of Income Tax (Appeals), NFAC erred ... attended the hearing. 1.1 The appellant submits that similar additions made in appellant's own case have been fully deleted by the Commissioner (Appeals) for the Asst. Year 2012-13, 2014-15, 2015-16 and 2018-19. 2.0 The learned Commissioner of Income Tax (Appeals), NFAC erred

M G B Motor and Auto Agencies Private Limited, Kurnool vs. DCIT., Circle-1, Kurnool

In the result, appeal of the assessee is allowed

ITA 537/HYD/2024[2018-2019]Status: HeardITAT Hyderabad05 Dec 2024AY 2018-2019

Bench: Shri Manjunatha .G & Shri K.Narasimha Chary

For Appellant: Shri T. Chaitanya Kumar, ARFor Respondent: Shri Srinath Sadanala, Sr. AR
Section 143(3)Section 270ASection 40

include the following, namely:— (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or the Commissioner (Appeals) or the Commissioner or the Principal Commissioner, as the case may be, is satisfied that the explanation is bona fide and the assessee ... income determined on the basis of an estimate, if the accounts are correct and complete to the satisfaction of the Assessing Officer or the Commissioner (Appeals) or the Commissioner or the Principal Commissioner, as the case may be, but the method employed is such that the income cannot properly