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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)

M/S Janiyyathul Mustharshideen Charitable Trust, Malappuram vs. ITO Ward 1, Tirur

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

ITA 980/COCH/2022[2010-11]Status: DisposedITAT Cochin11 Sept 2023AY 2010-11

Bench: Shri Sanjay Arora, Accountantmemberand Shri Manomohan Das, Judicialmember Janiyyathul Mustharshideen The Income Tax Officer Charitable Trust Ward -1, Tirur Edayoor Post Vs. Malappuram 676554 [Pan:Aaatj6491Q] (Appellant) (Respondent) Assessee By: Shri Shameem Ahmed, Advocate Revenue By: Smt. J.M. Jamuna Devi, Sr. D.R. Date Of Hearing: 11.09.2023 Date Of Pronouncement: 11.09.2023 O R D E R Persanjay Arora, Am This Appeal By The Assessee Agitating The In Limine Dismissal Of It’S Appeal Vide Order Dated 31.10.2022 By The Commissioner Of Income Tax (Appeals), Income Tax Department [Cit(A)], Contesting It’S Assessment Under Section 143(3) Of The Income Tax Act, 1961 (‘The Act’) Dated 28.03.2013 For Assessment Year (Ay) 2010-11. 2. Brief Facts Of The Case Leading To The Instant Appeal Are That The Assessee, A Public Charitable Trust Constituted Under The Trust Deed Dated 28.06.1999 & Registered U/S.12Aa Of The Act W.E.F. 20.10.2005, Returned It’S Income For The Relevant Year (On 29.06.2010) At Nil Income, Claiming Exemption U/S.11 Of The Act On The Voluntary Contributions Received During The Year, I.E., Rs.12.18 Lakhs. The Same Was Denied By The Assessing Officer (Ao) As The Assessee Had, Subsequent To Its Registration Under Section 12Aa Of The Act On 20.10.2005, I.E., On 21/10/2005, Totally Amended It’S Object Clause, Which Rather Was Required To Be Ratified By The Hon'Ble

For Appellant: Shri Shameem Ahmed, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 11Section 12ASection 143(3)Section 192Section 250(6)

satisfy the test of an order under section 250(6) of the Act, which reads as under: - Procedure in appeal. 250. (1) The Commissioner (Appeals) shall fix a day and place for the hearing of the appeal, and shall give notice of the same to the appellant ... Assessing Officer against whose order the appeal is preferred. (2) …(5) (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. 3.2 Granting that the assessee did not respond

Aluminium Pechiney, New Delhi vs. DCIT, Circle-1(1)(1) Int. Tax., New Dehi

In the result, appeal is dismissed

ITA 9484/DEL/2019[2011-12]Status: DisposedITAT Delhi06 Sept 2023AY 2011-12

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey, Hon’Ble Vice-Assessment Year: 2010-11 With Assessment Year: 2011-12 With Assessment Year: 2010-11 Aluminium Pechiney, Vs. Dcit, C/O- Ca, Praveen Gambhir, Circle-1(1)(1), 87-B, Masjid Moth Ph-2, International Taxation, Dda Flats, G.K. 3, New Delhi New Delhi Pan :Aaica3338C (Appellant) (Respondent)

Section 143(3)Section 154

delay and admit the appeals for adjudication on merits. AY: 2010-11 3. This appeal arises out of order dated 24.07.2019 passed by learned Commissioner (Appeals) under section 154 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’). 4. Briefly the facts are, the assessee ... appellate 3 | P a g e ITA Nos.9483 & 9484/Del/2019 & 3410/Del/2016 AYs: 2010-11 & 2011-12 authority. While deciding the appeal of the assessee, learned Commissioner (Appeals) granted partial relief by reducing an amount of ₹ 1,08,22,488/-, being receipt towards supply of goods from the income determined. Thereafter

Aluminium Pechiney, New Delhi vs. DCIT, Circle-1(1)(1) Int. Tax., New Dehi

In the result, appeal is dismissed

ITA 9483/DEL/2019[ 2010-11]Status: DisposedITAT Delhi06 Sept 2023

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey, Hon’Ble Vice-Assessment Year: 2010-11 With Assessment Year: 2011-12 With Assessment Year: 2010-11 Aluminium Pechiney, Vs. Dcit, C/O- Ca, Praveen Gambhir, Circle-1(1)(1), 87-B, Masjid Moth Ph-2, International Taxation, Dda Flats, G.K. 3, New Delhi New Delhi Pan :Aaica3338C (Appellant) (Respondent)

Section 143(3)Section 154

delay and admit the appeals for adjudication on merits. AY: 2010-11 3. This appeal arises out of order dated 24.07.2019 passed by learned Commissioner (Appeals) under section 154 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’). 4. Briefly the facts are, the assessee ... appellate 3 | P a g e ITA Nos.9483 & 9484/Del/2019 & 3410/Del/2016 AYs: 2010-11 & 2011-12 authority. While deciding the appeal of the assessee, learned Commissioner (Appeals) granted partial relief by reducing an amount of ₹ 1,08,22,488/-, being receipt towards supply of goods from the income determined. Thereafter

M/S Aluminium Pechiney, New Delhi vs. DCIT (International Taxation), New Delhi

In the result, appeal is dismissed

ITA 3410/DEL/2016[2010-11]Status: DisposedITAT Delhi06 Sept 2023AY 2010-11

Bench: Shri G.S. Pannu, Hon’Ble & Shri Saktijit Dey, Hon’Ble Vice-Assessment Year: 2010-11 With Assessment Year: 2011-12 With Assessment Year: 2010-11 Aluminium Pechiney, Vs. Dcit, C/O- Ca, Praveen Gambhir, Circle-1(1)(1), 87-B, Masjid Moth Ph-2, International Taxation, Dda Flats, G.K. 3, New Delhi New Delhi Pan :Aaica3338C (Appellant) (Respondent)

Section 143(3)Section 154

delay and admit the appeals for adjudication on merits. AY: 2010-11 3. This appeal arises out of order dated 24.07.2019 passed by learned Commissioner (Appeals) under section 154 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’). 4. Briefly the facts are, the assessee ... appellate 3 | P a g e ITA Nos.9483 & 9484/Del/2019 & 3410/Del/2016 AYs: 2010-11 & 2011-12 authority. While deciding the appeal of the assessee, learned Commissioner (Appeals) granted partial relief by reducing an amount of ₹ 1,08,22,488/-, being receipt towards supply of goods from the income determined. Thereafter

Shri Ved Prakash Sharma, Mandideep vs. The ITO, Raisen

Appeal is allowed for statistical purpose

ITA 109/IND/2023[2015-16]Status: DisposedITAT Indore05 Sept 2023AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year:2015-16 Ved Prakash Sharma, Ito, 23-24, Micaply, Raisen बनाम/ Industrial Area, Mandideep, Vs. Distt. Raisen (Assessee / Appellant) (Revenue / Respondent) Pan: Acrps2997R Assessee By None Revenue By Shri Ashish Porwal, Sr Dr Date Of Hearing 04.09.2023 Date Of Pronouncement 05.09.2023

Section 143(3)Section 250(6)

record and after considering the revenue’s submissions. 3. Section 250(6) of the Income-tax Act, 1961 provides “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

Ashok Kumar Singh, Durg vs. Income Tax Officer-2(2), Bhilai, Durg

In the result, the assessee's appeal is allowed in terms of our observations above

ITA 150/RPR/2023[2010-11]Status: DisposedITAT Raipur04 Sept 2023AY 2010-11

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 150/Rpr/2023 "नधा"रण वष" / Assessment Year : 2010-11 Ashok Kumar Singh P-10, Rishab Green City, Pulgaon, Durg-491 001 (C.G) Pan : Bcfps1394K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-2(2), Bhilai (C.G.) ……""यथ" / Respondent

For Appellant: Shri S.R. Rao, AdvocateFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(3)Section 147Section 148Section 271(1)(c)Section 274

aforesaid order are culled out as under: “4. We have carefully examined the record as well as duly considered the rival contentions. Both the Commissioner (Appeals) as well as the ITAT have categorically held that in the present case, there is no record of satisfaction by the Assessing Officer that

Access Diamonds Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, Central Circle-7(1), Mumbai

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

ITA 600/MUM/2023[2012-13]Status: DisposedITAT Mumbai01 Sept 2023AY 2012-13

Bench: Shri Aby T. Varkey, Jm आयकर अपील सं/ I.T.A. No.600/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2012-13) Access Diamonds Pvt. Ltd बिधम/ Dcit, Central Circle-7(1) Office No. 15, Floor- Aayakar Bhavan, Vs. Mezzanine, Laxmidas Mumbai-400020. Khimji Market, 36/38, Kalbadevi Road, Vitthalwadi, Mumbai- 400002. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aahca0551C (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Vimal Punmiya Revenue By: Shri Dharmvir D Yadav (Sr. Dr) सुनवाई की तारीख / Date Of Hearing: 28/06/2023 घोषणा की तारीख /Date Of Pronouncement: 01/09/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Cit(A)-49, Mumbai Dated 30.06.2016 For Ay. 2012-13. 2. There Is A Delay Of 2366 Days [I.E, Six (6) Years & 05 Months] In Filing Of This Appeal Before This Tribunal. 3. First Of All Will Deal With The Application Filed By The Ld. Ar Of The Assessee Shri Manish Panwar For Condonation Of In-Ordinate Delay. It Is Noted That The Assessee Is A Private Limited Company Engaged In The Business Of Trading Of Gold Bullion & Bars. For The Assessment Year Under Appeal, The Assessee Had Filed Its Return Of Income After Declaring Loss Of Rs. (8,932)/- On 27.09.2012. The Return Of Income Was Initially Processed U/S.143 (1) Of The Income Tax Act, 1961. Thereafter, The Case Of Assessee Was Selected For Scrutiny.

For Appellant: Shri Vimal PunmiyaFor Respondent: Shri Dharmvir D Yadav (Sr. DR)
Section 143Section 143(3)

suitor." 3.3 In the case of S.S.M. Ahmed Hussain v. ITO [2017] 85 taxmann.com 351 (Madras), the assessee filed an appeal before the Commissioner (Appeals) along with an application for condonation of delay of 175 days. The assessee claimed that delay occurred since he was waiting outcome of penalty order ... Commissioner (Appeals) however refused to condone the delay. The ITAT as later (as also confirmed by the High Court) held that that the reason stated by the assessee in these cases is that he was waiting for the outcome of the penalty proceedings. Therefore, one has to consider, whether reasonable

Mr Gaurav Ajmera, Ratlam vs. DCIT Central Circle -2, Indore

Accordingly. Thus, this ground is allowed partly for statistical purpose

ITA 71/IND/2022[2017-18]Status: DisposedITAT Indore01 Sept 2023AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2017-18 Mr. Gaurav Ajmera, Dcit, बनाम/ 38, Ram Mohalla, Central Circle 2, Ratlam Indore. Vs. (Assessee / Appellant) (Revenue / Respondent) Pan: Aglpa8863C Assessee By Shri Pawan Ved, Advocate & Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 13.06.2023 Date Of Pronouncement 01.09.2023

Section 115BSection 131Section 132(4)Section 132ASection 143(3)Section 153ASection 153DSection 234ASection 271A

carried us to the provision of section 271AAB which prescribes thus: “Penalty where search has been initiated 271AAB. (1) The Assessing Officer or the Commissioner (Appeals) may, not- withstanding anything contained in any other provisions of this Act, direct that, in a case where search has been initiated under section

Mondelez India Foods P.Ltd, Mumbai vs. Asst CIT RG 5(1)(2), Mumbai

ITA 1518/MUM/2017[2012-13]Status: DisposedITAT Mumbai31 Aug 2023AY 2012-13

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 14ASection 234ASection 234C

assessee had assumed that a benefit has accrued to the overseas A.E. on account of AMP expenditure incurred by the assessee. The learned Commissioner (Appeals) has upheld the adjustment / addition proposed by the Transfer Pricing Officer simply relying upon his order passed in assessee‟s own case for assessment year ... this context, the Transfer Pricing Officer has also referred to similar dispute arising in the preceding assessment years. It is evident that the learned Commissioner (Appeals) has upheld the disallowance of royalty payment of trademark simply relying upon the order passed by him in assessee‟s own case for assessment

Mondelez India Foods P. Ltd, Mumbai vs. DCIT RG 5(1)(2), Mumbai

ITA 1240/MUM/2016[2011-12]Status: DisposedITAT Mumbai31 Aug 2023AY 2011-12

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

Section 143(3)Section 144C(13)Section 14ASection 234ASection 234C

assessee had assumed that a benefit has accrued to the overseas A.E. on account of AMP expenditure incurred by the assessee. The learned Commissioner (Appeals) has upheld the adjustment / addition proposed by the Transfer Pricing Officer simply relying upon his order passed in assessee‟s own case for assessment year ... this context, the Transfer Pricing Officer has also referred to similar dispute arising in the preceding assessment years. It is evident that the learned Commissioner (Appeals) has upheld the disallowance of royalty payment of trademark simply relying upon the order passed by him in assessee‟s own case for assessment

M/S. Khadi Grammodhyog Pratisthan, Bikaner vs. ADIT, CPC / ITO, Ward-1(2), Bangaluru / Bikaner

In the result, appeal of the assessee is partly allowed

ITA 87/JODH/2023[2019-20]Status: DisposedITAT Jodhpur31 Aug 2023AY 2019-20
Section 139(1)Section 139(4)Section 143(1)Section 250(6)

matter afresh unless forbidden from doing so by the statute." As per section 250(6) of the Act, it is the duty of the Commissioner (Appeals) to state a point in dispute, record the reasons and pass a speaking order. The Hon'ble Supreme Court in the case of Kranti ... Canara Bank v. V. K. Awasthy (2005) SC 2090 has held that nonspeaking orders by Tribunal, as well as Commissioner (Appeals), is violating the principle of natural justice and liable to be set aside. Accordingly, under the faceless appeal scheme, the Authorities are bound to pass the speaking order

Anu Kumar, Patna vs. Deputy/ACIT Central Circle-2, Patna

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 60/PAT/2023[2019-20]Status: DisposedITAT Patna31 Aug 2023AY 2019-20

Bench: Shri Sanjay Garg & Shri Girish Agrawal

For Appellant: Shri Rakesh Kumar, AdvocateFor Respondent: Smt. Rinku Singh, CIT, DR
Section 144BSection 144B(6)(vii)Section 144B(7)(vii)Section 250

representative, as the case may be, may request for personal hearing so as to make his oral submissions or present his case before the Commissioner (Appeals), through the National Faceless Appeal Centre, atider this Scheme, (3) The concerned Commissioner (Appeals) shall allow the request for personal hearing and communicate ... laid down by the Board. (5) Any examination or recording of the statement of the appellant or any other person shall be conducted by Commissioner (Appeals) under this Scheme, exclusively through video conferencing or video telephony, including use of any telecommunication application software which supports video conferencing or video telephony

Anu Kumar, Patna vs. Deputy/ACIT Central Circle-2, Patna

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 59/PAT/2023[2018-19]Status: DisposedITAT Patna31 Aug 2023AY 2018-19

Bench: Shri Sanjay Garg & Shri Girish Agrawal

For Appellant: Shri Rakesh Kumar, AdvocateFor Respondent: Smt. Rinku Singh, CIT, DR
Section 144BSection 144B(6)(vii)Section 144B(7)(vii)Section 250

representative, as the case may be, may request for personal hearing so as to make his oral submissions or present his case before the Commissioner (Appeals), through the National Faceless Appeal Centre, atider this Scheme, (3) The concerned Commissioner (Appeals) shall allow the request for personal hearing and communicate ... laid down by the Board. (5) Any examination or recording of the statement of the appellant or any other person shall be conducted by Commissioner (Appeals) under this Scheme, exclusively through video conferencing or video telephony, including use of any telecommunication application software which supports video conferencing or video telephony

Anu Kumar, Patna vs. Deputy/ACIT Central Circle-2, Patna

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 58/PAT/2023[2017-18]Status: DisposedITAT Patna31 Aug 2023AY 2017-18

Bench: Shri Sanjay Garg & Shri Girish Agrawal

For Appellant: Shri Rakesh Kumar, AdvocateFor Respondent: Smt. Rinku Singh, CIT, DR
Section 144BSection 144B(6)(vii)Section 144B(7)(vii)Section 250

representative, as the case may be, may request for personal hearing so as to make his oral submissions or present his case before the Commissioner (Appeals), through the National Faceless Appeal Centre, atider this Scheme, (3) The concerned Commissioner (Appeals) shall allow the request for personal hearing and communicate ... laid down by the Board. (5) Any examination or recording of the statement of the appellant or any other person shall be conducted by Commissioner (Appeals) under this Scheme, exclusively through video conferencing or video telephony, including use of any telecommunication application software which supports video conferencing or video telephony

Anu Kumar, Patna vs. Deputy/ACIT Central Circle-2, Patna

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 57/PAT/2023[2016-17]Status: DisposedITAT Patna31 Aug 2023AY 2016-17

Bench: Shri Sanjay Garg & Shri Girish Agrawal

For Appellant: Shri Rakesh Kumar, AdvocateFor Respondent: Smt. Rinku Singh, CIT, DR
Section 144BSection 144B(6)(vii)Section 144B(7)(vii)Section 250

representative, as the case may be, may request for personal hearing so as to make his oral submissions or present his case before the Commissioner (Appeals), through the National Faceless Appeal Centre, atider this Scheme, (3) The concerned Commissioner (Appeals) shall allow the request for personal hearing and communicate ... laid down by the Board. (5) Any examination or recording of the statement of the appellant or any other person shall be conducted by Commissioner (Appeals) under this Scheme, exclusively through video conferencing or video telephony, including use of any telecommunication application software which supports video conferencing or video telephony

Anu Kumar, Patna vs. Deputy/ACIT Central Circle-2, Patna

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 55/PAT/2023[2014-15]Status: DisposedITAT Patna31 Aug 2023AY 2014-15

Bench: Shri Sanjay Garg & Shri Girish Agrawal

For Appellant: Shri Rakesh Kumar, AdvocateFor Respondent: Smt. Rinku Singh, CIT, DR
Section 144BSection 144B(6)(vii)Section 144B(7)(vii)Section 250

representative, as the case may be, may request for personal hearing so as to make his oral submissions or present his case before the Commissioner (Appeals), through the National Faceless Appeal Centre, atider this Scheme, (3) The concerned Commissioner (Appeals) shall allow the request for personal hearing and communicate ... laid down by the Board. (5) Any examination or recording of the statement of the appellant or any other person shall be conducted by Commissioner (Appeals) under this Scheme, exclusively through video conferencing or video telephony, including use of any telecommunication application software which supports video conferencing or video telephony

Anu Kumar, Patna vs. Deputy/ACIT Central Circle-2, Patna

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 54/PAT/2023[2013-14]Status: DisposedITAT Patna31 Aug 2023AY 2013-14

Bench: Shri Sanjay Garg & Shri Girish Agrawal

For Appellant: Shri Rakesh Kumar, AdvocateFor Respondent: Smt. Rinku Singh, CIT, DR
Section 144BSection 144B(6)(vii)Section 144B(7)(vii)Section 250

representative, as the case may be, may request for personal hearing so as to make his oral submissions or present his case before the Commissioner (Appeals), through the National Faceless Appeal Centre, atider this Scheme, (3) The concerned Commissioner (Appeals) shall allow the request for personal hearing and communicate ... laid down by the Board. (5) Any examination or recording of the statement of the appellant or any other person shall be conducted by Commissioner (Appeals) under this Scheme, exclusively through video conferencing or video telephony, including use of any telecommunication application software which supports video conferencing or video telephony

ACIT, Circle-3(1)(1), Int. Taxation, New Delhi vs. Raytheon Company, Gurgaon

In the result, all the appeals of the Revenue for the

ITA 441/DEL/2023[2007-08]Status: DisposedITAT Delhi31 Aug 2023AY 2007-08

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

leviable only when: i) A person fails to offer an explanation or offers an explanation which is found by the AO or the Commissioner (Appeals) or the Principal Commissioner or Commissioner to be false, or ii) Such person offers an explanation which he is not able to substantiate and fails

DCIT, Circle 3(1)(1), International Taxation, New Delhi vs. Raytheon Company, United State

In the result, all the appeals of the Revenue for the

ITA 1392/DEL/2023[2016-17]Status: DisposedITAT Delhi31 Aug 2023AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

leviable only when: i) A person fails to offer an explanation or offers an explanation which is found by the AO or the Commissioner (Appeals) or the Principal Commissioner or Commissioner to be false, or ii) Such person offers an explanation which he is not able to substantiate and fails

DCIT, Circle 3(1)(1), International Taxation, New Delhi vs. Raytheon Company, United State

In the result, all the appeals of the Revenue for the

ITA 1391/DEL/2023[2015-16]Status: DisposedITAT Delhi31 Aug 2023AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A Nos.1383 To 1392/Del/2023 िनधा"रणवष"/Assessment Yeasrs:2004-05 To 2006-07, 2008-09 To 2011-12 & 2014-15 To 2016-17 बनाम Dcit, Raytheon Company Circle 3(1)(1), Vs. 870, Winter Steet, Int. Taxation, Waltham-Ma 02451, Room No. 416, Foreign Usa, 4Th Floor, E-2 Block, Usa. Dr. S.P. Mukherjee Civic Centre, J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent & आ.अ.सं/.I.T.A No.441/Del/2023 िनधा"रणवष"/Assessment Year:2007-08 बनाम Acit, Raytheon Company Circle 3(1)(1), Vs. C/O Srbc & Associates Int. Taxation, Llp, Golf View Corporate Room No. 416, Tower-B, Sector-42, 4Th Floor, E-2 Block, Sector Road, Gurgaon, Dr. S.P. Mukherjee Civic Centre, Haryana. J.L. Nehru Marg, New Delhi. Pan No. Aadcr3511P अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 271(1)(c)

leviable only when: i) A person fails to offer an explanation or offers an explanation which is found by the AO or the Commissioner (Appeals) or the Principal Commissioner or Commissioner to be false, or ii) Such person offers an explanation which he is not able to substantiate and fails