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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)

Smt Suruchi Satish Sarmalkar, Mumbai vs. ITO Ward-32(1)(1), Mumbai

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

ITA 5942/MUM/2025[2020-21]Status: DisposedITAT Mumbai19 Dec 2025AY 2020-21

Bench: Shri Sandeep Gosain& Shri Om Prakash Kant

Section 154Section 250Section 270A

Satish Sarmalkar, Mumbai. (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or95[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 ... determined on the basis of an estimate, if the accounts are correct and complete to the satisfaction of the Assessing Officer or95[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Commissioner or the Principal Commissioner, as the case may be, but the method employed is such that

Sh. Atar Singh, Faridabad vs. ITO Ward-1(1), Faridabad

In the result, Appeal of the Assessee is partly allowed

ITA 2732/DEL/2025[2012-13]Status: DisposedITAT Delhi19 Dec 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Amitabh Shuklai.T.A. No. 2732/Del/2025 (A.Y 2012-13) Sh. Atar Singh Vs Income Tax Officer House No. 5, Village, Gazipur, Ward 1(1) Gazipur Road, Faridabad, Faridabad, Haryana Haryana-121005 122001 Pan: Dmpps6598B Appellant Respondent Assessee By Sh. S.S. Nagar, Ca Revenue By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 29/10/2025 Date Of Pronouncement 19/12/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income Tax (Appeals)/National Faceless Appeal

Section 147Section 148Section 151Section 151(1)Section 69A

there was non-application of mind on the part of the Assessing Officer. The Appellate Tribunal was justified in confirming the order of the Commissioner (Appeals) and holding that the reopening of the assessment was bad in law.” 18. Hon’ble Delhi High Court in the case of Shamshad Khan

Sushil Mitruka, Siliguri vs. DCIT, Circle 1, Siliguri

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

ITA 2178/KOL/2025[2014-2015]Status: DisposedITAT Kolkata18 Dec 2025AY 2014-2015

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

support the order in appeal on any of the grounds decided against it. The Respondent-assessee had taken the ground of maintainability before Commissioner (Appeals) and, therefore, in the appeal filed by the Revenue, it could rely upon Rule 27 and advance his arguments, even though it had not filed

Amar Kumar Agarwal, Kolkata vs. D.C.I.T., CC - 4(3), Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

ITA 2007/KOL/2025[2021-2022]Status: DisposedITAT Kolkata18 Dec 2025AY 2021-2022

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &
Section 132Section 153ASection 44ASection 69A

entire sum of the said undisclosed sales as income of the assessee for the assessment year 1994-95. Such addition was confirmed by the Commissioner (Appeals). The Tribunal, however, held that "the entire sales could not have been added as income of the assessee, but only to the extent

DCIT, Central Circle-4(3), Kolkata vs. Arun Engineering Udyog Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 1955/KOL/2025[2022-23]Status: DisposedITAT Kolkata18 Dec 2025AY 2022-23

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Dcit, Central Circle 4(3), Arun Engineering Udyog Kolkata Private Limited Aaykar Bhawan Poorva, 151, A, Cotton Street Vs. 110 Shantipally, Kolkata-700107 Burrabazaar West Bengal Kolkata-700007, West Bengal (Appellant) (Respondent) Pan No. Aalca8127A Assessee By : Shri Miraj D. Shah, Ar Revenue By : Shri Ruchika Sharma, Dr Date Of Hearing: 04.12.2025 Date Of Pronouncement: 18.12.2025 O R D E R

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Ruchika Sharma, DR
Section 133(6)Section 143(2)Section 143(3)Section 68

absence of any such finding, it is held that the order passed by the Assessing Officer was utterly perverse and rightly interfered by the Commissioner (Appeals). The Tribunal re-appreciated the factual position and agreed with the Commissioner (Appeals). The Tribunal apart from taking into consideration, the legal effect

DCIT, Central Circle-4(3), Kolkata vs. Raja Shelters Private Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1760/KOL/2025[2022-23]Status: DisposedITAT Kolkata18 Dec 2025AY 2022-23

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

Section 132Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 68

assessee. Therefore, the Assessing Officer ignored the basic tenets of law before invoking his power under section 68. Fortunately, for the assessee, the Commissioner (Appeals) has done an elaborate factual exercise, took into consideration, the creditworthiness of the 13 companies the details of which were furnished by the assessee. More ... which fact has not been denied by the Assessing Officer. On going through the records and the net worth of the lender companies, the Commissioner (Appeals) has recorded the factual findings that the net worth of those companies is in cropes of rupees and they have declared income

Sushil Mitruka, Darjeeling vs. DCIT, Circle 1, Siliguri

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

ITA 1631/KOL/2025[2016-2017]Status: DisposedITAT Kolkata18 Dec 2025AY 2016-2017

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

support the order in appeal on any of the grounds decided against it. The Respondent-assessee had taken the ground of maintainability before Commissioner (Appeals) and, therefore, in the appeal filed by the Revenue, it could rely upon Rule 27 and advance his arguments, even though it had not filed

Sushil Mitruka, Darjeeling vs. DCIT, Circle 1, Siliguri

In the result, the appeal of the Revenue is dismissed and the appeals

ITA 1630/KOL/2025[2015-2016]Status: DisposedITAT Kolkata18 Dec 2025AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Section 139(1)Section 144BSection 147Section 148Section 148(2)

support the order in appeal on any of the grounds decided against it. The Respondent-assessee had taken the ground of maintainability before Commissioner (Appeals) and, therefore, in the appeal filed by the Revenue, it could rely upon Rule 27 and advance his arguments, even though it had not filed

DCIT, Circle-1, Siliguri vs. Sushil Mitruka, Siliguri

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

ITA 1613/KOL/2025[2017-18]Status: DisposedITAT Kolkata18 Dec 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri SK Tulsian, ARFor Respondent: Shri S.B. Chakraborthy, DR
Section 139(1)Section 144BSection 147Section 148Section 148(2)

support the order in appeal on any of the grounds decided against it. The Respondent-assessee had taken the ground of maintainability before Commissioner (Appeals) and, therefore, in the appeal filed by the Revenue, it could rely upon Rule 27 and advance his arguments, even though it had not filed

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Amar Kumar Agarwal, Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

ITA 1499/KOL/2025[2021-22]Status: DisposedITAT Kolkata18 Dec 2025AY 2021-22

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &
Section 132Section 153ASection 44ASection 69A

entire sum of the said undisclosed sales as income of the assessee for the assessment year 1994-95. Such addition was confirmed by the Commissioner (Appeals). The Tribunal, however, held that "the entire sales could not have been added as income of the assessee, but only to the extent

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Amar Kumar Agarawal, Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

ITA 1498/KOL/2025[2020-21]Status: DisposedITAT Kolkata18 Dec 2025AY 2020-21

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &
Section 132Section 153ASection 44ASection 69A

entire sum of the said undisclosed sales as income of the assessee for the assessment year 1994-95. Such addition was confirmed by the Commissioner (Appeals). The Tribunal, however, held that "the entire sales could not have been added as income of the assessee, but only to the extent

Deputy Commssioner of Income Tax, Central Circle-4(3), Kolkata vs. Amar Kumar Agarwal, Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

ITA 1497/KOL/2025[2018-19]Status: DisposedITAT Kolkata18 Dec 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &
Section 132Section 153ASection 44ASection 69A

entire sum of the said undisclosed sales as income of the assessee for the assessment year 1994-95. Such addition was confirmed by the Commissioner (Appeals). The Tribunal, however, held that "the entire sales could not have been added as income of the assessee, but only to the extent

Deputy Commissioner of Income Tax, Central Circle 4(3), Kolkata vs. Amar Kumar Agarwal, Kolkata

In the result, the appeals of the assessee are partly allowed and

ITA 1496/KOL/2025[2017-18]Status: DisposedITAT Kolkata18 Dec 2025AY 2017-18

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &
Section 132Section 153ASection 44ASection 69A

entire sum of the said undisclosed sales as income of the assessee for the assessment year 1994-95. Such addition was confirmed by the Commissioner (Appeals). The Tribunal, however, held that "the entire sales could not have been added as income of the assessee, but only to the extent

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Amar Kumar Agarwal, Kolkata

In the result, the appeals of the assessee are partly allowed and appeals of the Revenue are dismissed

ITA 1440/KOL/2025[2019-20]Status: DisposedITAT Kolkata18 Dec 2025AY 2019-20

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Siddarth Jhajharia, ARFor Respondent: S/shri Raja Sengupta &
Section 132Section 153ASection 44ASection 69A

entire sum of the said undisclosed sales as income of the assessee for the assessment year 1994-95. Such addition was confirmed by the Commissioner (Appeals). The Tribunal, however, held that "the entire sales could not have been added as income of the assessee, but only to the extent

Alpesh K. Ajmera HUF, Mumbai vs. Income Tax Officer Ward 18(1)(1), Mumbai

In the result, the appeal filed by the assessee stands

ITA 4041/MUM/2025[2011-12]Status: DisposedITAT Mumbai18 Dec 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 132Section 147Section 68Section 69

under section 10(38) - Assessing Officer did not believe transactions in question as genuine and treated entire sale proceeds as 'Incoте from Other Sources' Commissioner (Appeals) opined that in absence of any positive evidence, merely ON basis of suspicion, transactions could not be held to be not genuine Commissioner (Appeals

Ashok Hirachand Shah, Panvel vs. Assessing Officer Ward 2, Panvel

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

ITA 812/PUN/2025[2011-12]Status: DisposedITAT Pune17 Dec 2025AY 2011-12

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.812/Pun/2025 धििाारण वर्ा / Assessment Year : 2011-12 Ashok Hirachand Shah, Assessing Officer, Plot No. 4, Mangal Bunglow, Ward – 2, Panvel Road No. 5, Sector No. 19, Vs. New Panvel, Tal.-Panvel-410206 Pan : Acdps4800M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Ajinkya Shah Department By : Shri Rajesh Gawali Date Of Hearing : 09-12-2025 Date Of 17-12-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 20.01.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. Denial Of Natural Justice & Proper Opportunity The Learned Commissioner Of Income Tax (Appeals) Erred In Dismissing The Appeal Without Considering That The Appellant Was Denied Proper Opportunity & Natural Justice During The Assessment Proceedings. The Assessing Officer Called For Information At The Far End Of The Assessment Proceedings On 19/11/2018 & Despite The Appellant'S Authorized Representative Submitting The Details On 19/12/2018, The Ao Failed To Discuss Or Consider The Same. The Matter Ought To Have Been Remanded Back For Fresh Adjudication To Allow Proper Analysis Of The Transactions. 2. Addition Without Specifying The Section The Cit(A) Erred In Upholding The Addition Of Rs. 1,49,05,289/- Made By The Ao Without Specifying The Section Under Which The Addition Was Made. The Non-Mention Of The Specific Section Renders The Assessment Order Bad In Law, As It Violates The Principles Of Natural Justice & Transparency In Taxation. 3. Failure To Discharge Onus Under Section 69A

For Appellant: Shri Ajinkya ShahFor Respondent: Shri Rajesh Gawali
Section 147Section 69A

real in nature. Various surrounding circumstances had been relied upon by the Assessing Officer to reject the explanation offered by the Assessees. The Commissioner (Appeals) confirmed the findings and conclusion drawn by the Assessing Officer. The Tribunal concurred with the findings of fact. The findings were based on the material

Rohini Maruti Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1839/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

ordered by the Assessing Authority. The Commissioner of Income-tax (Appeals), however, deleted the said penalty. The order of the Commissioner (Appeals) was appealed against before the Income-tax Appellate Tribunal (hereinafter referred to "the Tribunal") which confirmed the order of the Commissioner (Appeals) and dismissed the appeal filed ... revenue. However, the revenue challenged the said order before the High Court which confirmed the orders passed by the Commissioner (Appeals) and the Tribunal while dismissing the Tax Appeal filed by the revenue. 3. Few facts would be relevant. 4. The assessee is a company and the relevant assessment year

Tulsabai Vasant Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1838/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

ordered by the Assessing Authority. The Commissioner of Income-tax (Appeals), however, deleted the said penalty. The order of the Commissioner (Appeals) was appealed against before the Income-tax Appellate Tribunal (hereinafter referred to "the Tribunal") which confirmed the order of the Commissioner (Appeals) and dismissed the appeal filed ... revenue. However, the revenue challenged the said order before the High Court which confirmed the orders passed by the Commissioner (Appeals) and the Tribunal while dismissing the Tax Appeal filed by the revenue. 3. Few facts would be relevant. 4. The assessee is a company and the relevant assessment year

Amol Vasant Deshmukh, Pune vs. Income Tax Officer, Ward 6(2), Pune

In the result, all the appeals (ITA Nos

ITA 1837/PUN/2025[2015-16]Status: DisposedITAT Pune17 Dec 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Sarang Gudhate, CAFor Respondent: Shri Manoj Tripathi, Addl.CIT
Section 250Section 271(1)(c)Section 44ASection 54B

ordered by the Assessing Authority. The Commissioner of Income-tax (Appeals), however, deleted the said penalty. The order of the Commissioner (Appeals) was appealed against before the Income-tax Appellate Tribunal (hereinafter referred to "the Tribunal") which confirmed the order of the Commissioner (Appeals) and dismissed the appeal filed ... revenue. However, the revenue challenged the said order before the High Court which confirmed the orders passed by the Commissioner (Appeals) and the Tribunal while dismissing the Tax Appeal filed by the revenue. 3. Few facts would be relevant. 4. The assessee is a company and the relevant assessment year

M/S B.N. Dutta, Jamshedpur vs. DCIT, Cir. 2, Durgapur

The appeal of the assessee is allowed for statistical purposes

ITA 705/KOL/2024[2011-12]Status: DisposedITAT Kolkata17 Dec 2025AY 2011-12

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.705/Kol/2024 Assessment Year: 2011-12 M/S B. N. Dutta ….…………………………………………………..………….……Appellant Head Office: 518, G Road, Sonari West Layout, Jamshedpur, Jharkhand – 831011. [Pan: Aadfb0648J] Vs. Dcit, Circle-2, Durgapur……..……....….….. ……………….........……...…..…..Respondent Appearances By: Shri D. Khasnobis, Ca & None Appeared On Behalf Of The Appellant. Shri H. Robindro Singh, Addl. Cit - Dr & None Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2025 & December 17, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 13.02.2024 Of The Commissioner Of Income Tax (Appeals), Indore [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is Partnership Firm & Engaged In The Business Of Civil Construction & Maintenance Of Civil Structures Inside Stell Plants. For The Assessment Year 2011-12, The Assessee Filed Its Return On 30.09.2011 By Declaring Total Income Of Rs.36,58,080/- & Total Tax & Cess Liability Of Rs.11,30,347/- Was Discharged In Full Resulting In A Refund Of Rs.12,520/-. The Return Of The Assessee Was Processed By The Cpc U/S 143(1) Of The Act On 27.01.2012. The Assessee Did Not Receive Any Information From The Cpc Either Directly By Way Of Service Of Physical Copy Of The Same Or From The Then Authorised Representative Namely Mr. S. N. Gupta. Due To Non-Receipt Of

Section 143(1)Section 249(3)Section 250

reproduced as under for the sake of ready reference: 6)The order of the [* * *] [ Omitted by Act 21 of 1998, Section 65 (w.e.f. 1.10.1998).] [Commissioner (Appeals)] [ Inserted by Act 29 of 1977, Section 39 and Schedule V (w.e.f. 10.7.1978).] disposing of the appeal shall be in writing and shall state ... points for determination, the decision thereon and the reason for the decision. [(6-A) In every appeal, the Commissioner (Appeals), where it is possible, may hear and decide such appeal within a period of one year from the end of the financial year in which such appeal is filed before