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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 Care India Solution for Sustainable Development, Delhi vs. DCIT, Central Circle-14, Delhi

ITA 7437/DEL/2025[2016-17]Status: DisposedITAT Delhi09 Mar 2026AY 2016-17

Bench: Sh. Raj Kumar Chauhan & Smt. Renu Jauhri

For Appellant: Sh. Pratik Arora, CAFor Respondent: Sh. Amit Jain, CIT-DR
Section 11Section 12ASection 147Section 148Section 148ASection 151Section 25Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL DELHIBENCH `E', NEW DELHI Before Sh. Raj Kumar Chauhan, Judicial Member & Smt. Renu Jauhri

Vimal Todi, Indore vs. Additional Commissioner of Income Tax, Indore

Appeal is allowed

ITA 188/IND/2024[2012-13]Status: DisposedITAT Indore06 Mar 2026AY 2012-13

Bench: Shri B.M. Biyani & Shri Paresh M Joshishri Vimal Todi, Additional Commissioner बनाम/ 501, Darshan Residency, Of Income-Tax, Vs. 104-105, Anand Bazar, Indore Indore

Section 132Section 254(2)Section 271DSection 275Section 275(1)(c)

Chapter shall be passed-- (a) in a case where the relevant assessment or other order is the subject-matter of an appeal to the Commissioner (Appeals) under section 246 or section 246A or an appeal to the Appellate Tribunal under section 253, after the expiry of the financial year ... imposition of penalty has been initiated, are completed, or six months from the end of the month in which the order of the Commissioner (Appeals) or, as the case may be, the Appellate Tribunal is received by the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner, whichever

Income Tax Officer, Ward-9(1), Kolkata vs. Littlestar Securities Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 694/KOL/2025[2012-13]Status: DisposedITAT Kolkata06 Mar 2026AY 2012-13

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

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Manjeet Singh, DR
Section 143(3)Section 144BSection 254Section 68

assessee. The entire share capital raised by the assessee was added to the assessee's income under section 68. On appeal, the Commissioner (Appeals) was satisfied that the share capital and share premium were given through banking channels, that the identity and creditworthiness of the parties were not in doubt

Mescab India Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2128/KOL/2025[2014-2015]Status: DisposedITAT Kolkata06 Mar 2026AY 2014-2015

Bench: the AO all the evidences qua these unsecured loans such as names, addresses, PANs, audited accounts, confirmations etc. The also AO issued letters to all the loan creditors u/s 133(6) of the Act which were all replied by the loan creditors by furnishing all the details such as copies of the ITRs, audited balance sheets, bank statements, loan confirmation etc. as called for by the AO. However, the AO, by making casual remarks about money laundering and rejecting all the evidences, treated th

Section 133(6)Section 250Section 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

Mescab India Private Limited, Kolkata vs. D.C.I.T., Circle - 11(1), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2127/KOL/2025[2013-2014]Status: DisposedITAT Kolkata06 Mar 2026AY 2013-2014

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 133(6)Section 250Section 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

Nagaraju Muniyappa, Kaggalipura Post, Kanakapu Bade Katte vs. Income Tax Officer Ward 7(2)(5), Bangalore, Karnataka

In the result, the appeal is allowed for statistical purposes

ITA 2499/BANG/2025[2016-17]Status: DisposedITAT Bangalore05 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

For Appellant: Shri Siddesh Gaddi, CAFor Respondent: Shri Subramanian, JCIT (DR)
Section 144Section 250Section 251(1)(a)

examined the materials available on record. Section 251(1)(a) of the Act provides that in an appeal against an order of assessment, the Commissioner (Appeals) may confirm, reduce, enhance or annul the assessment. 8.1 By virtue of the amendment effective from 01.10.2024, a specific proviso has been inserted empowering ... Commissioner (Appeals), in cases where the assessment has been framed u/s 144 of the Act, to set . Page 5 of 7 aside the assessment and refer the case back to the AO for making a fresh assessment. 8.2 The legislative intent behind the amendment, as evident from the explanatory memorandum

Pakarahalli Narayanappa Srinivasgowda, Bangalore vs. Income Tax Officer, Ward-6(3)(1), Bangalore

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

ITA 1373/BANG/2025[2016-17]Status: DisposedITAT Bangalore05 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2016-17

For Appellant: Shri Ravishankar, AdvocateFor Respondent: Shri Subramanian, JCIT (DR)
Section 148Section 250Section 254

From the above, it is evident that the view limiting the Tribunal’s jurisdiction to the issues arising solely from the appeal before the Commissioner (Appeals) is too restrictive to define the Tribunal’s powers. The Tribunal undoubtedly has the discretion to permit or decline the raising

Portescap India Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 2(3)(1), Mumbai

In the result, the appeal filed by the assessee is allowed in light of aforesaid directions

ITA 7479/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 Mar 2026AY 2019-20

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhailassessment Year : 2019-20 Portescap India Private Limited, The Deputy Commissioner Of Unit No. 101, Tower Ii, Income Tax, Seepz Sez, Vs. Circle-2(3)(1), Andheri East, Room No. 552, 5Th Floor, Seepz S.O., Aayakar Bhavan, Mumbai-400096. M.K.Road, Pan : Aaack4896K Mumbai-400020. (Appellant) (Respondent) For Assessee : Shri Pranay Gandhi A/W. Shri Lekh Mehta, For Revenue : Shri R.A. Dhyani, Cit-Dr Date Of Hearing : 17-02-2026 Date Of Pronouncement : 05-03-2026 O R D E R Per Vikram Singh Yadav, A.M :

For Appellant: Shri Pranay Gandhi a/wFor Respondent: Shri R.A. Dhyani, CIT-DR
Section 10ASection 143(1)Section 143(1)(a)Section 154Section 234BSection 250Section 43B

further submitted that against the said intimation, the assessee moved a rectification application on 31-05-2021 and also filed appeal before the Commissioner (Appeals). The Commissioner (Appeals) disposed- off the assessee‟s appeal vide order dt. 29-02-2024, wherein he has deleted the disallowance of gratuity claim

M/S. Avm Productions, Chennai vs. ACIT, Non Corporate Circle-20(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 2359/CHNY/2025[2017-18]Status: DisposedITAT Chennai04 Mar 2026AY 2017-18

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

Section 270Section 270A

extract of Section 270A is reproduced as under: "270A. Penalty for under reporting misreporting of income, etc.- (1) If the Assessing Officer or the Commissioner (Appeals) or Principal Commissioner or Commissioner may during the course of any proceeding under this act, direct that any person who has under reported

Amit Shantaram Bagade Mited, Mumbai vs. Income Tax Officer Int Taxation Ward 1(2), Mumbai

In the result, both the appeals filed by the assessee are partly allowed

ITA 832/MUM/2025[2019-20]Status: DisposedITAT Mumbai04 Mar 2026AY 2019-20

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rohan Despande &For Respondent: Shri Krishna Kumar, Sr.DR
Section 132Section 142(1)Section 147Section 148Section 148ASection 151ASection 69

assessee was not acceded to by the Assessing Officer. When the assessee took up the aforesaid issue before the first appellate authority, the learned Commissioner (Appeals) in letter dated 18th July 2016, had clearly directed the Assessing Officer to provide the assessee all adverse materials /documentary evidences available with ... with all the adverse material and if, not so, whether he has provided them to the assessee as per the directions of the learned Commissioner (Appeals). Thus, from the aforesaid facts, it is patent and obvious that the addition of 42 lakh made on account of on-money payment

Amit Shantaram Bagade, Thane vs. ITO (Int Tax) Ward-1(2)(1), Mumbai

In the result, both the appeals filed by the assessee are partly allowed

ITA 6286/MUM/2025[2020-21]Status: DisposedITAT Mumbai04 Mar 2026AY 2020-21

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Rohan Despande &For Respondent: Shri Krishna Kumar, Sr.DR
Section 132Section 142(1)Section 147Section 148Section 148ASection 151ASection 69

assessee was not acceded to by the Assessing Officer. When the assessee took up the aforesaid issue before the first appellate authority, the learned Commissioner (Appeals) in letter dated 18th July 2016, had clearly directed the Assessing Officer to provide the assessee all adverse materials /documentary evidences available with ... with all the adverse material and if, not so, whether he has provided them to the assessee as per the directions of the learned Commissioner (Appeals). Thus, from the aforesaid facts, it is patent and obvious that the addition of 42 lakh made on account of on-money payment

Mahaveer Singh, Ahmedabad vs. The PCIT, Ahmedabad-1, Ahmedabad

In the result, the appeal filed by the Assessee is hereby dismissed

ITA 840/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad03 Mar 2026AY 2018-19

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

Section 139(1)Section 142(1)Section 143(3)Section 148Section 234FSection 263(1)Section 270ASection 270A(2)(b)Section 272A(1)(d)Section 44A

case of under reporting of income. For ready reference Section 270A(2)(b) is reproduced as follows: “270A. (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 ... under: Section 271(1)(c) [Failure to furnish returns, comply with notices, concealment of income, etc. 271. (1) If the (Assessing Officer or the Commissioner (Appeals) any proceedings under this Act, is satisfied that nay person- (b)……………… or (c) has concealed the particulars of "his income or so*** "furnished inaccurate

Menakuru Sukumar Reddy, Hyderabad vs. DCIT(A), Chennai

ITA 993/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Mar 2026AY 2017-18
Section 143(3)Section 147Section 148Section 251(2)Section 69A

held that: “Section 251 of the Income-tax Act, 1961 (Corresponding to section 31(3) of the Indian Income-tax Act, 1922) - Commissioner (Appeals) - Powers of - Assessment year 1947-48 - Whether it would not be open to AAC to introduce into assessment new sources, as his power of enhancement

Menakuru Sukumar Reddy, Hyderabad vs. DCIT(A), Chennai

In the result the appeal of the revenue is dismissed

ITA 992/CHNY/2025[2016-17]Status: DisposedITAT Chennai02 Mar 2026AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. P. Murali Mohana Rao, CAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(3)Section 147Section 148Section 251(2)Section 69A

held that: “Section 251 of the Income-tax Act, 1961 (Corresponding to section 31(3) of the Indian Income-tax Act, 1922) - Commissioner (Appeals) - Powers of - Assessment year 1947-48 - Whether it would not be open to AAC to introduce into assessment new sources, as his power of enhancement

Menakuru Sukumar Reddy, Hyderabad vs. DCIT(A), Chennai

In the result the appeal of the revenue is dismissed

ITA 991/CHNY/2025[2015-16]Status: DisposedITAT Chennai02 Mar 2026AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. P. Murali Mohana Rao, CAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(3)Section 147Section 148Section 251(2)Section 69A

held that: “Section 251 of the Income-tax Act, 1961 (Corresponding to section 31(3) of the Indian Income-tax Act, 1922) - Commissioner (Appeals) - Powers of - Assessment year 1947-48 - Whether it would not be open to AAC to introduce into assessment new sources, as his power of enhancement

ACIT, Chennai vs. Menakuru Sukumar Reddy, Chennai

ITA 1644/CHNY/2025[2017-18]Status: DisposedITAT Chennai02 Mar 2026AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 991, 992 & 993/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16, 2016-17 & 2017-18 Menakuru Sukumar Reddy, 8-2-696-697, Road No.2, Banjara Hills, Hyderabad - 500 034. [Pan: Aabhm-8414-M] (अपीलार्थी/Appellant) Dcit, Vs. Central Circle -3(4), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.: 1639 & 1644/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16 & 2017-18 Acit, Central Circle -3(4), Chennai. (अपीलार्थी/Appellant) Menakuru Sukumar Reddy, Vs. 8-2-696-697, Road No.2, Banjara Hills, Hyderabad - 500 034. [Pan: Aabhm-8414-M] (प्रत्यर्थी/Respondent) Assessee By : Shri. P. Murali Mohana Rao, Ca Department By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 04.12.2025 घोषणा की तारीख/Date Of Pronouncement : 02.03.2026 आदेश /Order Per S. R. Raghunatha, Am : :-2-:

For Appellant: Shri. P. Murali Mohana Rao, CAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143Section 143(3)Section 147Section 148Section 251(2)Section 69A

held that: “Section 251 of the Income-tax Act, 1961 (Corresponding to section 31(3) of the Indian Income-tax Act, 1922) - Commissioner (Appeals) - Powers of - Assessment year 1947-48 - Whether it would not be open to AAC to introduce into assessment new sources, as his power of enhancement

ACIT, Chennai vs. Menakuru Sukumar Reddy, Chennai

ITA 1639/CHNY/2025[2015-16]Status: DisposedITAT Chennai02 Mar 2026AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 991, 992 & 993/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16, 2016-17 & 2017-18 Menakuru Sukumar Reddy, 8-2-696-697, Road No.2, Banjara Hills, Hyderabad - 500 034. [Pan: Aabhm-8414-M] (अपीलार्थी/Appellant) Dcit, Vs. Central Circle -3(4), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.: 1639 & 1644/Chny/2025 निर्धारण वर्ष / Assessment Years: 2015-16 & 2017-18 Acit, Central Circle -3(4), Chennai. (अपीलार्थी/Appellant) Menakuru Sukumar Reddy, Vs. 8-2-696-697, Road No.2, Banjara Hills, Hyderabad - 500 034. [Pan: Aabhm-8414-M] (प्रत्यर्थी/Respondent) Assessee By : Shri. P. Murali Mohana Rao, Ca Department By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 04.12.2025 घोषणा की तारीख/Date Of Pronouncement : 02.03.2026 आदेश /Order Per S. R. Raghunatha, Am : :-2-:

For Appellant: Shri. P. Murali Mohana Rao, CAFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 143(3)Section 147Section 148Section 251(2)Section 69A

held that: “Section 251 of the Income-tax Act, 1961 (Corresponding to section 31(3) of the Indian Income-tax Act, 1922) - Commissioner (Appeals) - Powers of - Assessment year 1947-48 - Whether it would not be open to AAC to introduce into assessment new sources, as his power of enhancement

Bhairav Tube (India), Mumbai vs. Income Tax Officer Ward 19(1)(2), Mumbai

ITA 5494/MUM/2025[2009-10]Status: DisposedITAT Mumbai02 Mar 2026AY 2009-10

Bench: Hon’Ble Justice (Retd.) C.V. Bhadang & Shri Arun Khodpia, Am

Section 271(1)(c)Section 275(1)(a)

proviso to s.275(1)(a). 3. That the Ld. AO ought to have taken cognizance of the subject assessment order being challenged before the Commissioner (Appeals) and subsequently before the Hon. Income Tax Appellate Tribunal and kept in abeyance the penalty proceedings till the disposal of the said appeals

Jagan Mohan Rao Valluru, Vijayawada vs. Deputy Commissioner of Income Tax, Circle-2(1), Vijayawada

ITA 469/VIZ/2025[2009-10]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2009-10

Bench: Shri Ravish Sood, Hon'Ble & Shri Omkareshwar Chidara, Hon'Bleआयकर अपीलसं./I.T.A.No.468/Viz/2025 (निर्धारण वर्ष / Assessment Year:2009-10) Sai Sri Anusha Valluru 62-8, Flat No. 201 Kesava Residency Netaji Street, Patamata Vijayawada [Pan: Ahopv5451H] Vs. Dcit – Circle-2(1) C.R. Building, 1St Floor Annex M.G.Road, Vijayawada-520002 Andhra Pradesh आयकर अपीलसं./I.T.A.No.469/Viz/2025 (निर्धारण वर्ष / Assessment Year:2009-10) Jagan Mohan Rao Valluru Vs. Dcit – Circle-2(1) 63-1-3, Ramalayam Street Patamatalanka Vijayawada – 520010 Andhra Pradesh [Pan: Ahopv4864A] C.R. Building, 1St Floor Annex M.G.Road, Vijayawada-520002 Andhra Pradesh करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement : Shri C. Subrahmanyam, Ca : Shri D. Hema Bhupal, Sr.Dr : 16.02.2026 : 27.02.2026 Per Ravish Sood, Jm: आदेश /Order

Section 143(3)Section 147Section 148Section 154Section 250(6)

appellate order has been passed in violation of the mandatory provisions of Section 250(6) of the Income-tax Act, 1961, which require the Commissioner (Appeals) to state the points for determination, the decision thereon, and the reasons for the decision. Page. No 2 I.T.A.No.468/VIZ/2025 Sai Sri Anusha Valluru

Sai Sri Anusha Valluru, Vijayawada vs. Deputy Commissioner of Income Tax, Circle-2(1), Vijayawada

ITA 468/VIZ/2025[2009-10]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2009-10

Bench: Shri Ravish Sood, Hon'Ble & Shri Omkareshwar Chidara, Hon'Bleआयकर अपीलसं./I.T.A.No.468/Viz/2025 (निर्धारण वर्ष / Assessment Year:2009-10) Sai Sri Anusha Valluru 62-8, Flat No. 201 Kesava Residency Netaji Street, Patamata Vijayawada [Pan: Ahopv5451H] Vs. Dcit – Circle-2(1) C.R. Building, 1St Floor Annex M.G.Road, Vijayawada-520002 Andhra Pradesh आयकर अपीलसं./I.T.A.No.469/Viz/2025 (निर्धारण वर्ष / Assessment Year:2009-10) Jagan Mohan Rao Valluru Vs. Dcit – Circle-2(1) 63-1-3, Ramalayam Street Patamatalanka Vijayawada – 520010 Andhra Pradesh [Pan: Ahopv4864A] C.R. Building, 1St Floor Annex M.G.Road, Vijayawada-520002 Andhra Pradesh करदाता का प्रतिनिधित्व/ Assessee Represented By राजस्व का प्रतिनिधित्व/ Department Represented By सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing घोषणा की तारीख/Date Of Pronouncement : Shri C. Subrahmanyam, Ca : Shri D. Hema Bhupal, Sr.Dr : 16.02.2026 : 27.02.2026 Per Ravish Sood, Jm: आदेश /Order

Section 143(3)Section 147Section 148Section 154Section 250(6)

appellate order has been passed in violation of the mandatory provisions of Section 250(6) of the Income-tax Act, 1961, which require the Commissioner (Appeals) to state the points for determination, the decision thereon, and the reasons for the decision. Page. No 2 I.T.A.No.468/VIZ/2025 Sai Sri Anusha Valluru