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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)

Nimus Projects Limited, Delhi vs. DCIT, Central Circle-2, Noida

The appeal are disposed of as not pressed

ITA 5015/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 132Section 142(1)Section 147Section 148Section 69C

adduced any rebuttal evidence to show that entries made in diary/loose sheets were not income in hands of assessee, addition upheld by Commissioner (Appeals) and Tribunal were justified-Held, yes" From the above judgments, it is clear that once there is adequate documentary proof available showing the payment of cash

Nimbus Projects Limited, Delhi vs. DCIT, Central Circle-2, Noida

The appeal are disposed of as not pressed

ITA 5014/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 132Section 142(1)Section 147Section 148Section 69C

adduced any rebuttal evidence to show that entries made in diary/loose sheets were not income in hands of assessee, addition upheld by Commissioner (Appeals) and Tribunal were justified-Held, yes" From the above judgments, it is clear that once there is adequate documentary proof available showing the payment of cash

Numbus Projects Limited, Delhi vs. DCIT, Central Circle-2, Noida

The appeal are disposed of as not pressed

ITA 5013/DEL/2025[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 132Section 142(1)Section 147Section 148Section 69C

adduced any rebuttal evidence to show that entries made in diary/loose sheets were not income in hands of assessee, addition upheld by Commissioner (Appeals) and Tribunal were justified-Held, yes" From the above judgments, it is clear that once there is adequate documentary proof available showing the payment of cash

Best Bull Stock Trading Pvt Ltd., New Delhi vs. ACIT, Central Circle-18, New Delhi

In the result, the appeals of the revenue in ITA No

ITA 2954/DEL/2024[2016-17]Status: DisposedITAT Delhi09 Jan 2026AY 2016-17

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

action for assessment, reassessment or recomputation may be taken. Section 251 reads as follows: Powers of the 70 [Joint Commissioner (Appcals) or the) Commissioner (Appeals). 251. (1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers- (a) in an appeal against an order of assessment ... other case, he may pass such orders in the appeal as he thinks fit. (1A) In disposing of an appeal, the Joint Commissioner (Appeals) shall have the following powers- (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment

Best Bull Stock Trading Pvt Ltd., New Delhi vs. ACIT Central Circle-18, Delhi

In the result, the appeals of the revenue in ITA No

ITA 2953/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Sh. C.N. Prasad & Sh. M. Balaganesh

Section 132Section 147Section 148Section 150Section 150(1)Section 150(2)Section 153(6)Section 153A

action for assessment, reassessment or recomputation may be taken. Section 251 reads as follows: Powers of the 70 [Joint Commissioner (Appcals) or the) Commissioner (Appeals). 251. (1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers- (a) in an appeal against an order of assessment ... other case, he may pass such orders in the appeal as he thinks fit. (1A) In disposing of an appeal, the Joint Commissioner (Appeals) shall have the following powers- (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment

Assistant Commissioner of Income Tax, Central Circle-25 New Delhi, Delhi vs. Faridabad Presswell Pvt Ltd, Delhi

In the result, the appeal of the

ITA 2801/DEL/2024[2015-16]Status: DisposedITAT Delhi09 Jan 2026AY 2015-16

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.2801/Del/2024 िनधा"रणवष"/Assessment Year: 2015-16 बनाम Assistant Commissioner Of Faridabad Presswell Pvt. Ltd. Income Tax, Vs. 24, Ashoka Chamber, 5B, Central Circle-25, Room No.317, Rajindra Park, Pusa Road, 3Rd Floor, E-2, Ara Centre, New Delhi. Jhandewalan Extension, Pan No. Aaacfs815B Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 250

been stated therein, as reproduced below: "...In the instant case, the assessee had raised the point of non-recording o f reason before the Commissioner (Appeals) though the around was not so categorical. Even so, such ground could be inferred from the fact that the assessee had been repeatedly asking ... reopening had been recorded, but due to some difficulty or the other, the department had not been able to produce the records. The Commissioner (Appeals) had not recorded any finding on the question whether the reasons were recorded or not, but having regard to the judgment of the Delhi High

Deputy Commissioner of Income Tax, Circle-4(2), Delhi vs. Crystal Crop Protection Limited, Delhi

Accordingly, we find no error in the order of Ld. CIT(A) which is hereby uphold. Accordingly, grounds of appeal No. 2 & 3 of the Revenue are dismissed

ITA 2379/DEL/2023[2013-14]Status: DisposedITAT Delhi09 Jan 2026AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2330/Del/2023 (Assessment Year 2018-19) Dy. Cit, Crystal Crop Protection Circle-4(2), Delhi. Limited, Vs. B-95, Wazirpur, Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) C.O. No.159/Del/2023 Arising Out Of Ita No.2330/Del/2023 (Assessment Year 2018-19) Crystal Crop Protection Dy. Cit, Limited, Circle-4(2), Delhi. B-95, Wazirpur, Vs. Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) Assessee By Shri S.S. Nagar, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 30.10.2025 Date Of Pronouncement 09.01.2026 C.O. No.159/Del/2023 Dcit Vs. Crystal Crop Protection Limited O R D E R Per Manish Agarwal, Am: The Captioned Two Appeals Are Filed By The Revenue & Cross Objection Is Filed By The Assessee For Following Assessment Years.

Section 1Section 143(3)Section 148Section 37(1)

forth hereafter: "7. We have considered rival submissions and perused the materials on record. The basic grievance of the Revenue is, learned Commissioner (Appeals) should not have deleted the addition based on additional evidences furnished by the assessee without forwarding them to the Assessing Office for his examination and opinion ... terminus with the Assessing Officer. On a reading of section 250 and 251 of the Act, it is very much clear that learned Commissioner (Appeals) while deciding an appeal can consider and decide any matter arising out of proceedings in which the order appealed against was passed, notwithstanding that such

DCIT Circle 4(2), New Delhi vs. Crystal Crop Protection Limited, Delhi

Accordingly, we find no error in the order of Ld. CIT(A) which is hereby uphold. Accordingly, grounds of appeal No. 2 & 3 of the Revenue are dismissed

ITA 2330/DEL/2023[2018-19]Status: DisposedITAT Delhi09 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalita No.2330/Del/2023 (Assessment Year 2018-19) Dy. Cit, Crystal Crop Protection Circle-4(2), Delhi. Limited, Vs. B-95, Wazirpur, Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) C.O. No.159/Del/2023 Arising Out Of Ita No.2330/Del/2023 (Assessment Year 2018-19) Crystal Crop Protection Dy. Cit, Limited, Circle-4(2), Delhi. B-95, Wazirpur, Vs. Industrial Area Delhi, Delhi-110052. Pan-Aabcj3574E (Appellant) (Respondent) Assessee By Shri S.S. Nagar, Ca Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 30.10.2025 Date Of Pronouncement 09.01.2026 C.O. No.159/Del/2023 Dcit Vs. Crystal Crop Protection Limited O R D E R Per Manish Agarwal, Am: The Captioned Two Appeals Are Filed By The Revenue & Cross Objection Is Filed By The Assessee For Following Assessment Years.

Section 1Section 143(3)Section 148Section 37(1)

forth hereafter: "7. We have considered rival submissions and perused the materials on record. The basic grievance of the Revenue is, learned Commissioner (Appeals) should not have deleted the addition based on additional evidences furnished by the assessee without forwarding them to the Assessing Office for his examination and opinion ... terminus with the Assessing Officer. On a reading of section 250 and 251 of the Act, it is very much clear that learned Commissioner (Appeals) while deciding an appeal can consider and decide any matter arising out of proceedings in which the order appealed against was passed, notwithstanding that such

Alok Kumar Rungta, Lucknow vs. NFAC, Delhi

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

ITA 598/LKW/2025[2014-15]Status: DisposedITAT Lucknow08 Jan 2026AY 2014-15

Bench: Shri Kul Bharatassessment Year: 2014-15 Alok Kumar Rungta V. National Faceless Appeal B-40 Flat No.34 Manoram Centre Apartment Aliganj, Lucknow- Delhi. 226024. Pan:Ajqpr0755G (Appellant) (Respondent) Appellant By: Shri Vijay Prakash Agarwal, Advocate Shri Akshay Agarwal, Advocate Respondent By: Shri R. R. N. Shukla, Addl Cit(Dr) Date Of Hearing: 28 10 2025 Date Of Pronouncement: 08 01 2026 O R D E R

For Appellant: Shri Vijay Prakash Agarwal, AdvocateFor Respondent: Shri R. R. N. Shukla, Addl CIT(DR)
Section 1Section 143(3)Section 147Section 148Section 150(1)

clarity, section 251 of the Income Tax Act, 1961 (“Act”, for short) is reproduced as under: - “251. (1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers— (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment ... other case, he may pass such orders in the appeal as he thinks fit. [(1A) In disposing of an appeal, the Joint Commissioner (Appeals) shall have the following powers— (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment

Income Tax Officer, Khanna vs. Rohit Gupta, Khanna

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

ITA 861/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh08 Jan 2026AY 2015-16

Bench: it is finally disposed of.

For Appellant: NoneFor Respondent: Shri Rajat Kumar Kureel, CIT, DR
Section 144Section 147Section 148Section 251(1)(a)Section 69

compliance. The proviso to section 251(1)(a) of the Act, inserted by the Finance Act, 2024 with effect from 01.10.2024, specifically empowers the Commissioner (Appeals) to set aside an assessment made under section 144 and to refer the case back to the Assessing Officer for making a fresh assessment

Material Research Instruments, Mumbai vs. ACIT-Circle16(2), Mumbai

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

ITA 4084/MUM/2025[2006-07]Status: DisposedITAT Mumbai08 Jan 2026AY 2006-07

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 147Section 50C

Transfer charges paid to Society Brokerage 69,767 Long Term Capital 1,05,94,837 Gain 7. In appeal, the learned Commissioner (Appeals), while affirming the applicability of section 50C with reference to the 5 Material Research Instruments stamp duty value as on the date of registration, considered it appropriate ... fair market value at ₹71,06,000/- as on 05.08.2005 and at ₹12,52,000/- as on 01.04.1981. Relying upon this report, the learned Commissioner (Appeals) upheld the adoption of stamp duty value as on the date of registration and directed recomputation of capital gains by adopting

Assistant Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Ritu Dhingra, Shakti Vihar, Haibowal Kalan, Ludhiana

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

ITA 862/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh07 Jan 2026AY 2019-20

Bench: him:- (a) That the assessment order dated 31.03.2023 passed u/s 143(3) r.w.s.153C is bad in law in as much no incriminating material was found suggesting any escapement of income at premises of Sh. Avtar Singh Kochhar. (b) That the assessment order passed is non-est and bad in law in as much the proceedings have not been conducted in the manner prescribed by the Department instructions from time to time which are mandatory for compliance by the Learned Authorities particularly with respect

For Appellant: Shri Ashwani Kumar, C.A and Ms. Deepali Aggarwal, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR
Section 131Section 132Section 143(3)Section 144Section 153CSection 153C(3)Section 153DSection 250Section 251(1)(a)

fresh assessment by invoking amended provisions of section 251(1)(a) which are reproduced as below: "251. (1) In disposing of an appeal, the [***] [Commissioner (Appeals)] shall have the following powers- (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment: [Provided

Ritu Dhingra, Ludhiana vs. Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

ITA 645/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh07 Jan 2026AY 2019-20

Bench: him:-

For Appellant: Shri Ashwani Kumar, C.A and Ms. Deepali Aggarwal, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR
Section 131Section 132Section 143(3)Section 144Section 153CSection 153C(3)Section 153DSection 250Section 251(1)(a)

fresh assessment by invoking amended provisions of section 251(1)(a) which are reproduced as below: "251. (1) In disposing of an appeal, the [***] [Commissioner (Appeals)] shall have the following powers- (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment: [Provided

Jonang Buddhist Educational Society, Kangra, Himachal Pradesh vs. Commissioner of Income Tax, Exemptions, Chandigarh

In the result, Assessee’s appeal is dismissed

ITA 1350/CHANDI/2025[2025-26]Status: DisposedITAT Chandigarh07 Jan 2026AY 2025-26

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Krinwant Sahay, Am आयकर अपील सं./ Ita No.1350/Chd/2025 (िनधा"रण वष" / Assessment Year: 2025-26) Jonang Buddhist Educational Commissioner Of Society Income बनाम/ C/O Tejmohan Singh, Advocate Tax Exemptions, Vs. #527, Sector 10-D, Chandigarh Chandigarh 160011 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aafaj-8024-M (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ : Sh. Tej Mohan Singh (Advocate) Appellant By ""थ"कीओरसे/Respondent : Sh. Manav Bansal (Cit) Dr By सुनवाईकीतारीख/Date Of Hearing : 16-12-2025 घोषणाकीतारीख /Date Of : 07- 01-2026 Pronouncement आदेश / O R D E R Krinwant Sahay () Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 03.09.2025 Passed By The Ld.

For Respondent: Sh. Manav Bansal (CIT) DR by
Section 10ASection 12ASection 80GSection 80G(5)(iii)

procedural compliances, with the Central Board of Direct Taxes. Similarly, the timelines prescribed for completion or disposal of proceedings by the Assessing Officer, the Commissioner (Appeals), or other authorities, including those contemplated under section 144C of the Act, are matters governed by the statutory framework itself. The Tribunal, while exercising

Moorthy Ramasubramanian, Tuticorin vs. DCIT, Circle-1, Tirnelveli

In the result, the appeal of the assessee is allowed

ITA 2007/CHNY/2025[2018-19]Status: DisposedITAT Chennai07 Jan 2026AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadish

For Appellant: Shri H. Yeshwanth Kumar, AdvocateFor Respondent: Ms. R. Anitha, Addl.CIT
Section 143(1)Section 143(3)Section 144BSection 145(3)

argued to be unlawful, as section 145(3) was not applicable to the facts. The Assessing Officer erred in rejecting the books, and the Commissioner (Appeals) failed to appreciate this defect. The addition of Rs.6,00,000/- as undisclosed - 4 - ITA No.2007/CHNY/2025 business income is claimed to be arbitrary, unsupported ... facts, and wrongly upheld by the Commissioner (Appeals). Ld.AR furthermore, stated that the Assessing Officer allegedly made baseless estimations of unaccounted income and sales, including extrapolating figures for 12 months and for periods beyond the survey, without any rational basis. Admissions made during the survey, according to the assessee, cannot

Bholenath Foods Limited, New Delhi vs. Deputy Commissioner of Income Tax, Circle- 4(2), New Delhi

The appeal of the assessee is disposed of in above terms

ITA 5777/DEL/2024[2012-13]Status: DisposedITAT Delhi07 Jan 2026AY 2012-13

Bench: Shri Raj Kumar Chauhan & Shri Manish Agarwalassessment Year : 2012-13 Bholenath Foods Limited, Vs. Income Tax Officer, Shop No.208, Ward 47(1), Bldg. No.2612/13, Naya Bazar, New Delhi. Delhi – 110 006. Pan: Aabcb3842P

For Appellant: Shri Shivam Yadav, Advocate &For Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 133ASection 142(1)Section 143(2)Section 147Section 148Section 250Section 68

order to prove the genuineness of the business transactions. 11. Section 250, sub-section (6) read 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

Laxmi Venkatesh Credit Co-Operative Society Limited, Udupi vs. Income Tax Officer, Ward-1 & Tps, Udupi

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

ITA 2046/BANG/2025[2018-19]Status: DisposedITAT Bangalore06 Jan 2026AY 2018-19

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2018-19

For Appellant: None
Section 56Section 57Section 80P(2)(a)

section 253 of the Act, the appeal to the Appellate Tribunal will lie against the order passed by the Deputy Commissioner (Appeals) or Commissioner (Appeals) only. In the present case, there is no grievance for the assessee against the Ld.CIT(A) order but their only grievance is against the order ... order of the Ld.CIT(A), then the proper course of action to be taken under the provisions of the Act is to approach the Commissioner (Appeals). Admittedly, the assessee had not challenged the said order before the Ld.CIT(A). In such circumstances, we do not find that the present appeal

Kulsum Aaqib Memon, Mumbai vs. DCIT, C. Circle 4(2), Mumbai

In the result, the appeal of the assessee being ITA No

ITA 6540/MUM/2025[2021-22]Status: DisposedITAT Mumbai06 Jan 2026AY 2021-22

Bench: Shri Anikesh Banerjee & Shri Bijayananda Prusethkulsum Aaqib Memon, Vs The Deputy Commissioner Of 1201, Park View, 25 Mehraj Income Tax, Central Circle 4(2), Sethi Marg, Agripada, Mumbai Mumbai-400008 Kautilya Bhawan, G Block Bkc, Bandra Kurla Complex, Mumbai Pan: Cbypm9748Q 400051 Appellant Respondent Assessee By : Shri Rakesh Joshi, Respondent By : Shri Ritesh Misra (Cit Dr) Date Of Hearing : 16/12/2025 Date Of Pronouncement : 06/01/2026 O R D E R Per: Anikesh Banerjee (Jm): 1. The Instant Appeal Of The Assessee Filed Against The Order Of The Ld. Commissioner Of Income Tax (Appeal)-52, Mumbai [For Brevity The “Ld. Cit(A)”], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2021-22, Date Of Order 13.09.2025. The Impugned Order Emanated From The Order Of The Ld. Deputy Commissioner Of Income Tax, C.C.-4(2)

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Ritesh Misra (CIT DR)
Section 132Section 143(3)Section 153CSection 250Section 69

opportunity goes to root of the matter and strikes at the very foundation of the assessment and, therefore, renders the orders passed by the Commissioner (Appeals) and the Tribunal vulnerable. The assessee was bound to be provided with the material used against him apart from being permitting him to cross

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

In the result, all the appeals filed by the assessee are allowed

ITA 6511/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Jan 2026AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 30Section 56

additions made for these years are liable to be deleted on this jurisdictional ground alone. Nevertheless, since the Assessing Officer and the learned Commissioner (Appeals) have dealt with the merits of the additions at considerable length, and since extensive submissions have been advanced before us on merits as well

Deepak Kakubhai Mehta, Mumbai vs. DCIT, Central Circle 4(1), Mumbai

ITA 6510/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Jan 2026AY 2017-18
Section 1Section 132Section 132(4)Section 133ASection 143(3)Section 153ASection 153CSection 153DSection 30Section 56

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI ARUN KHODPIA, ACCOUNTANT MEMBER