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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)

Repal Renewables Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 481/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.116 & 481/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Repal Renewables Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aagcr9762B (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 115JSection 143(3)Section 153Section 234Section 234BSection 234DSection 270A

notifications, if any. (c) Appeals by taxpayers/ tax authorities against anv quasi- judicial order:- Wherever any appeal is required to filed before Joint Additional Commissioner (Appeals), Commissioner (Appeals), Appellate Authority for Advance Ruling. Tribunal and various courts against any quasi-judicial order or where a proceeding for revision or rectification ... Supreme Court vide its Order dated 27.04.2021 is applicable in respect of any appeal which is required to be filed before Joint Additional Commissioner (Appeals), Commissioner (Appeals), 17 ITA.Nos.116 & 481/Hyd./2022 Appellate Authority for Advance Ruling, Tribunal and various courts against any quasi-judicial order or where proceeding

Repal Green Power Private Limited, Hyderabad vs. DCIT Circle -3(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 474/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022 Assessment Year 2017-2018 Repal Green Power Private Limited, The Dcit, Circle-8(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) आ.अपी.सं /Ita No.474/Hyd/2022 Assessment Year 2018-2019 Repal Green Power Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aahcr2187F (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)Section 234Section 234DSection 270ASection 32Section 32A

notifications, if any. (c) Appeals by taxpayers/ tax authorities against anv quasi- judicial order:- Wherever any appeal is required to filed before Joint Additional Commissioner (Appeals), Commissioner (Appeals), Appellate Authority for Advance Ruling. Tribunal and various courts against any quasi-judicial order or where a proceeding for revision or rectification ... Supreme Court vide its Order dated 27.04.2021 is applicable in respect of any appeal which is required to be filed before Joint Additional Commissioner (Appeals), Commissioner (Appeals), Appellate Authority for Advance Ruling, Tribunal and various courts against any quasi-judicial order or where proceeding for revision or rectification

Repal Green Power Private Limited, Hyderabad vs. DCIT, Circle 8(1), Hyderabad

ITA 125/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.125/Hyd/2022

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 143(3)Section 234Section 234DSection 270ASection 32Section 32A

notifications, if any. (c) Appeals by taxpayers/ tax authorities against anv quasi- judicial order:- Wherever any appeal is required to filed before Joint Additional Commissioner (Appeals), Commissioner (Appeals), Appellate Authority for Advance Ruling. Tribunal and various courts against any quasi-judicial order or where a proceeding for revision or rectification ... Supreme Court vide its Order dated 27.04.2021 is applicable in respect of any appeal which is required to be filed before Joint Additional Commissioner (Appeals), Commissioner (Appeals), Appellate Authority for Advance Ruling, Tribunal and various courts against any quasi-judicial order or where proceeding for revision or rectification

Repal Renewables Private Limited, Hyderabad vs. DCIT, Circle 8(1), Hyderabad

In the result, both the appeals of the Assessee are allowed

ITA 116/HYD/2022[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.116 & 481/Hyd/2022 Assessment Years 2017-2018 & 2018-2019 Repal Renewables Private Limited, The Dcit, Circle-3(1), Vs. Hyderabad. Hyderabad – 500 081 Pan Aagcr9762B (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Sri Harsh R Shah, Advocate & Ca Karan Jain राज" व "ारा /Revenue By: Ms U Mini Chandran, Cit-Dr

For Appellant: Sri Harsh R Shah, Advocate &For Respondent: MS U Mini Chandran, CIT-DR
Section 115JSection 143(3)Section 153Section 234Section 234BSection 234DSection 270A

notifications, if any. (c) Appeals by taxpayers/ tax authorities against anv quasi- judicial order:- Wherever any appeal is required to filed before Joint Additional Commissioner (Appeals), Commissioner (Appeals), Appellate Authority for Advance Ruling. Tribunal and various courts against any quasi-judicial order or where a proceeding for revision or rectification ... Supreme Court vide its Order dated 27.04.2021 is applicable in respect of any appeal which is required to be filed before Joint Additional Commissioner (Appeals), Commissioner (Appeals), 17 ITA.Nos.116 & 481/Hyd./2022 Appellate Authority for Advance Ruling, Tribunal and various courts against any quasi-judicial order or where proceeding

Quantum Real Estate & Property Development India Pvt Ltd, Mumbai vs. Income Tax Officer, WD-11(1)(1), Mumbai

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

ITA 4591/MUM/2025[2009-10]Status: DisposedITAT Mumbai26 Nov 2025AY 2009-10

Bench: Shri Sandeep Gosain& Shri Prabhash Shankara.Ys: 2009-10

Section 133(6)Section 250Section 68

Mumbai. held that “In course of assessment, Assessing Officer made additions to assessee's income under section 68 in respect of trade advances Commissioner (Appeals) and Tribunal deleted said addition finding that trade advances received by assessee were adjusted against sales made in subsequent years High Court upheld order passed

Vijaya Prakash Nagori, Mumbai vs. ITO Ward 32(2)(1), Mumbai

ITA 3392/MUM/2025[2014-15]Status: DisposedITAT Mumbai26 Nov 2025AY 2014-15

Bench: Hon’Ble Shri Sandeep Gosain& Shri Om Prakash Kantvijaya Prakash Nagori Vs. Ito, Ward, 32(2)(1) 409/C, Abhar Jp Road, Kautilya Bhawan, C-41- Seven Bungalows, Andhere 43, Avenue, 3, Near (W), Mumbai – 400 061. Videsh Bhavan, G Block Bkc Pan/Gir No. Aekpr2943H (Applicant) (Respondent)

Section 10(38)Section 147Section 263oSection 68

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 ... Assessing Officer rejected assessee's plea and made additions under sections 68 and 69 by relying on statements from 'entry operators' - On appeal, Commissioner (Appeals) accepted assessee's claim, noting that shares were purchased via Account Payee Cheques, held in a Demat Account for over 12 months, and sold through

Dy. Commissioner of Income Tax, Noida vs. Star Landcraft Private Limited, Ghaziabad

In the result, appeal of the Revenue in ITA No

ITA 4117/DEL/2025[2022-23]Status: DisposedITAT Delhi26 Nov 2025AY 2022-23

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 143(2)Section 148Section 37Section 41Section 68Section 69Section 69ASection 69C

office that the assessee/third parties furnished the relevant evidences. The said evidences were called for under the powers of enquiry with the office of Commissioner Appeal). Hence, the assessee/third parties have not produced any additional evidence but have only furnished evidences as called tor during enquiry made by this office ... held as under: "Whether a distinction should be recognized and maintained between a case where assessee invokes rule 46A to adduce additional evidence before Commissioner (Appeals) and a case where Commissioner (Appeals), without being prompted by assessee, while dealing with appeal, considers it fit to cause or make a further

Dy. Commissioner of Income Tax, Noida vs. Star Landcraft Private Limited, Ghaziabad

In the result, appeal of the Revenue in ITA No

ITA 4116/DEL/2025[2020-21]Status: DisposedITAT Delhi26 Nov 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 143(2)Section 148Section 37Section 41Section 68Section 69Section 69ASection 69C

office that the assessee/third parties furnished the relevant evidences. The said evidences were called for under the powers of enquiry with the office of Commissioner Appeal). Hence, the assessee/third parties have not produced any additional evidence but have only furnished evidences as called tor during enquiry made by this office ... held as under: "Whether a distinction should be recognized and maintained between a case where assessee invokes rule 46A to adduce additional evidence before Commissioner (Appeals) and a case where Commissioner (Appeals), without being prompted by assessee, while dealing with appeal, considers it fit to cause or make a further

Dy Commissioner of Income Tax, Noida vs. M/S Allure Developers Private Limited, Delhi

In the result, appeal of the Revenue in ITA No

ITA 4108/DEL/2025[2021-22]Status: DisposedITAT Delhi26 Nov 2025AY 2021-22

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 143(2)Section 148Section 37Section 41Section 68Section 69Section 69ASection 69C

office that the assessee/third parties furnished the relevant evidences. The said evidences were called for under the powers of enquiry with the office of Commissioner Appeal). Hence, the assessee/third parties have not produced any additional evidence but have only furnished evidences as called tor during enquiry made by this office ... held as under: "Whether a distinction should be recognized and maintained between a case where assessee invokes rule 46A to adduce additional evidence before Commissioner (Appeals) and a case where Commissioner (Appeals), without being prompted by assessee, while dealing with appeal, considers it fit to cause or make a further

Deputy Commissioner of Income Tax Central Circle 1 Noida, Noia vs. M/S Ajay Realcon Pvt. Ltd., Noida

In the result, appeal of the Revenue in ITA No

ITA 3560/DEL/2025[2020]Status: DisposedITAT Delhi26 Nov 2025

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 143(2)Section 148Section 37Section 41Section 68Section 69Section 69ASection 69C

office that the assessee/third parties furnished the relevant evidences. The said evidences were called for under the powers of enquiry with the office of Commissioner Appeal). Hence, the assessee/third parties have not produced any additional evidence but have only furnished evidences as called tor during enquiry made by this office ... held as under: "Whether a distinction should be recognized and maintained between a case where assessee invokes rule 46A to adduce additional evidence before Commissioner (Appeals) and a case where Commissioner (Appeals), without being prompted by assessee, while dealing with appeal, considers it fit to cause or make a further

Deputy Commissioner of Income Tax Central Circle 1 Noida, Noida vs. M/S Allure Developers Pvt. Ltd, New Delhi

In the result, appeal of the Revenue in ITA No

ITA 3559/DEL/2025[2020]Status: DisposedITAT Delhi26 Nov 2025

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 143(2)Section 148Section 37Section 41Section 68Section 69Section 69ASection 69C

office that the assessee/third parties furnished the relevant evidences. The said evidences were called for under the powers of enquiry with the office of Commissioner Appeal). Hence, the assessee/third parties have not produced any additional evidence but have only furnished evidences as called tor during enquiry made by this office ... held as under: "Whether a distinction should be recognized and maintained between a case where assessee invokes rule 46A to adduce additional evidence before Commissioner (Appeals) and a case where Commissioner (Appeals), without being prompted by assessee, while dealing with appeal, considers it fit to cause or make a further

Deputy Commissioner of Income Tax Central Circle 1 Noida, Noida vs. M/S Allure Developers Private Limited, Noida

In the result, appeal of the Revenue in ITA No

ITA 3558/DEL/2025[2019]Status: DisposedITAT Delhi26 Nov 2025

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 143(2)Section 148Section 37Section 41Section 68Section 69Section 69ASection 69C

office that the assessee/third parties furnished the relevant evidences. The said evidences were called for under the powers of enquiry with the office of Commissioner Appeal). Hence, the assessee/third parties have not produced any additional evidence but have only furnished evidences as called tor during enquiry made by this office ... held as under: "Whether a distinction should be recognized and maintained between a case where assessee invokes rule 46A to adduce additional evidence before Commissioner (Appeals) and a case where Commissioner (Appeals), without being prompted by assessee, while dealing with appeal, considers it fit to cause or make a further

Deputy Commissioner of Income Tax Central Circle 1 Noida, Noida vs. M/S Ace Residency Pvt. Ltd, Ghaziabad

In the result, appeal of the Revenue in ITA No

ITA 3493/DEL/2025[2021]Status: DisposedITAT Delhi26 Nov 2025

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

Section 132Section 139(1)Section 143(2)Section 148Section 37Section 41Section 68Section 69Section 69ASection 69C

office that the assessee/third parties furnished the relevant evidences. The said evidences were called for under the powers of enquiry with the office of Commissioner Appeal). Hence, the assessee/third parties have not produced any additional evidence but have only furnished evidences as called tor during enquiry made by this office ... held as under: "Whether a distinction should be recognized and maintained between a case where assessee invokes rule 46A to adduce additional evidence before Commissioner (Appeals) and a case where Commissioner (Appeals), without being prompted by assessee, while dealing with appeal, considers it fit to cause or make a further

Ajit Rameshchandra Pathak, Surat vs. DCIT, Circle 1(1)(1), Surat (Prev. J.O. ACIT, Circle 1(2), Surat)

In the result, the appeal of the assessee is allowed

ITA 726/SRT/2025[2017-18]Status: DisposedITAT Surat25 Nov 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri Sunil Taladi, CAFor Respondent: Shri Ajay Uke, Sr. DR
Section 69A

Trib.) where it was held that where cash deposited in bank account of assessee was treated as unexplained cash credit by Assessing Officer but Commissioner (Appeals) having found that money withdrawn by assessee from bank account might be available for subsequent deposit, directed Assessing Officer to take only peak credit ... there was no infirmity in order of Commissioner (Appeals). In the case of C. Vamsi Mohan v. ITO ITA.No.469/Hyd/2014 the ITAT held that said withdrawal having been made by the assessee just before a week, the same can reasonably be treated as available with the assessee for cash deposit

Madhya Pradesh Police Housing Corporation Limited, Bhopal vs. DCIT-2(1), Bhopal

Appeal is allowed for statistical purpose

ITA 109/IND/2025[2008-09]Status: DisposedITAT Indore25 Nov 2025AY 2008-09

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 143(3)Section 154

adjudication by CIT(A) on merit in accordance with provisions of 250(6) of the Act which 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

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Jugal Kishore Garg Alias Sh. Jugal Kishore Derewala, Jaipur

10. In view of the provisions of section 271D, 271E and 275(1) of the Act,

ITA 1320/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Nov 2025AY 2016-17
For Appellant: Shri S.L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT
Section 269SSection 269TSection 271DSection 271E

shall be passed- [(a) in a case where the relevant assessment or other order is the subject-matter of an appeal to the [*] [Joint Commissioner (Appeals) or to the] Commissioner (Appeals) under section 246 [or section 246A] or an appeal to the Appellate Tribunal under section 253 after the expiry ... penalty has been initiated, are completed, or six months from the end of the month in which the order of the 74[*] 74[Joint Commissioner (Appeals) or the] Commissioner (Appeals) or, as the case may be, the Appellate Tribunal is received by the 75 [Principal Chief Commissioner or] Chief Commissioner

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Jugal Kishore Garg Alias Sh. Jugal Kishore Derewala, Jaipur

10. In view of the provisions of section 271D, 271E and 275(1) of the Act,

ITA 1319/JPR/2025[2012-13]Status: DisposedITAT Jaipur25 Nov 2025AY 2012-13
For Appellant: Shri S.L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT
Section 269SSection 269TSection 271DSection 271E

shall be passed- [(a) in a case where the relevant assessment or other order is the subject-matter of an appeal to the [*] [Joint Commissioner (Appeals) or to the] Commissioner (Appeals) under section 246 [or section 246A] or an appeal to the Appellate Tribunal under section 253 after the expiry ... penalty has been initiated, are completed, or six months from the end of the month in which the order of the 74[*] 74[Joint Commissioner (Appeals) or the] Commissioner (Appeals) or, as the case may be, the Appellate Tribunal is received by the 75 [Principal Chief Commissioner or] Chief Commissioner

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Jugal Kishore Garg Alias Sh. Jugal Kishore Derewala, Jaipur

10. In view of the provisions of section 271D, 271E and 275(1) of the Act,

ITA 1318/JPR/2025[2012-13]Status: DisposedITAT Jaipur25 Nov 2025AY 2012-13
For Appellant: Shri S.L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT
Section 269SSection 269TSection 271DSection 271E

shall be passed- [(a) in a case where the relevant assessment or other order is the subject-matter of an appeal to the [*] [Joint Commissioner (Appeals) or to the] Commissioner (Appeals) under section 246 [or section 246A] or an appeal to the Appellate Tribunal under section 253 after the expiry ... penalty has been initiated, are completed, or six months from the end of the month in which the order of the 74[*] 74[Joint Commissioner (Appeals) or the] Commissioner (Appeals) or, as the case may be, the Appellate Tribunal is received by the 75 [Principal Chief Commissioner or] Chief Commissioner

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipurq, Jaipur vs. Jugal Kishore Garg Alias Sh. Jugal Kishore Derewala, Jaipur

ITA 1317/JPR/2025[2016-17]Status: DisposedITAT Jaipur25 Nov 2025AY 2016-17

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri S.L. Poddar, AdvFor Respondent: Shri Rajesh Ojha, CIT
Section 269SSection 269TSection 271DSection 271E

shall be passed- [(a) in a case where the relevant assessment or other order is the subject-matter of an appeal to the [*] [Joint Commissioner (Appeals) or to the] Commissioner (Appeals) under section 246 [or section 246A] or an appeal to the Appellate Tribunal under section 253 after the expiry ... penalty has been initiated, are completed, or six months from the end of the month in which the order of the 74[*] 74[Joint Commissioner (Appeals) or the] Commissioner (Appeals) or, as the case may be, the Appellate Tribunal is received by the 75 [Principal Chief Commissioner or] Chief Commissioner

Swaminath Baburao Patil, Solapur vs. ITO Ward 2(3) Solapur, Solapur

In the result, appeal of the Assessee is allowed for statistical purpose

ITA 832/PUN/2025[2014-2015]Status: DisposedITAT Pune25 Nov 2025AY 2014-2015

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.832/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15 Swaminath Baburao Patil, V The Income Tax Officer, C37, Siddheshwar Market S Ward-2(3), Solapur. Yard, Hyderabad Road, Solapur – 431005. Maharashtra. Pan: Akwpp4321P Appellant/ Assessee Respondent / Revenue Assessee By Shri Girish Ladda Revenue By Shri Ambarnath Khule (Through Virtual Hearing) – Jcit(Dr) Date Of Hearing 24/11/2025 Date Of Pronouncement 25/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2014-15 Dated 27.01.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Act, Dated 19.05.2023. The Assessee Has Raised The Following Grounds Of Appeal :

Section 139(1)Section 143(2)Section 147Section 148Section 148ASection 151ASection 153CSection 249(4)(a)Section 250Section 292B

prescribed form6 and shall be verified in the prescribed manner 7[and shall, in case of an appeal made to the Commissioner (Appeals) on or after the 1st day of October, 1998, irrespective of the date of initiation of the assessment proceedings relating thereto be accompanied ... Provided that, 16[in a case falling under clause (b) and] on an application made by the appellant in this behalf, the 17[* * *] 18[Commissioner (Appeals)] may, for any good and sufficient reason to be recorded in writing, exempt him from the operation of the provisions of 19[that clause