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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)

14 Reels Venkatboyanapalli Jv, Hyderabad vs. DCIT, Central Circle - 1(3), Hyderabad

In the result, both the appeals of the Assessee are allowed for statistical purposes

ITA 617/HYD/2025[2018-19]Status: DisposedITAT Hyderabad12 Nov 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita Nos.617 & 969/Hyd./2025 िनधा"रण वष"/Assessment Years 2018-2019 & 2017-2018 14 Reels The Dcit, Central Venkatboyanapalli Jv, Circle-1(3), Hyderabad. Vs. Hyderabad – 500 033. Pin – 500 004. Pan Aaaaz2224L Telangana. (Appellant) (Respondent) िनधा""रती "ारा /Assessee By : Mrs. K Prabhabati, Advocate राज" व "ारा /Revenue By : Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06.11.2025 घोषणा की तारीख/Pronouncement: 12.11.2025 आदेश/Order Per Vijay Pal Rao: These Two Appeals By The Assessee Are Directed Against The Two Separate Orders Of The Learned Cit(A), Hyderabad- 11, Hyderabad, Dated 08.02.2025 & 13.03.2025 For The Assessment Years 2018-2019 & 2017-2018, Respectively.

For Appellant: Mrs. K Prabhabati, AdvocateFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 250

natural justice. 2. The ld. Commissioner of Income Tax (Appeals)-11, Hyderabad, erred in dismissing the appeal for want of prosecution. The ld. Commissioner (Appeals) failed to appreciate that as per the provisions of section 250/251 of the Act, the ld. Commissioner (Appeals) cannot dismiss the appeal for alleged ... prosecution'. 3. Without prejudice to above grounds, the Id. Commissioner (Appeals) erred in sustaining the additions of Rs.1,10,00,000 and Rs.3,10,00,000 as unexplained income of the Appellant. 4. Without prejudice to the above grounds, the Id. Commissioner (Appeals) erred in sustaining the action

Haribabu Yenuganti, Ongole vs. Income Tax Officer, Ward-1, Ongole

ITA 1476/HYD/2025[2017-18]Status: HeardITAT Hyderabad12 Nov 2025AY 2017-18

Bench: Us:

Section 147Section 148Section 156Section 249Section 249(4)Section 249(4)(b)Section 250Section 69A

Provided that, 2 in a case falling under clause (b) and) on an application made by the appellant in this behalf, the 3 Deputy Commissioner (Appeals)]4 or, as the case may be, the Commissioner (Appeals)] may, for any good and sufficient reason to be recorded in writing exempt ... Provided that, in a case falling under clause (b) and on an application made by the appellant in this behalf, the [Joint Commissioner (Appeals) or the] Commissioner (Appeals) may, for any good and sufficient reason to be recorded in writing, exempt him from the operation of the provisions of that

Lilaram, Mumbai vs. DCIT Central Circle 4(2), Mumbai

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

ITA 5557/MUM/2025[2019-20]Status: DisposedITAT Mumbai12 Nov 2025AY 2019-20

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 132Section 153Section 153CSection 254(1)Section 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

Akhraj Pukhraj Chopra, Mumbai vs. DCIT Central Circle 4(2), Mumbai

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

ITA 5555/MUM/2025[2020-21]Status: DisposedITAT Mumbai12 Nov 2025AY 2020-21

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 132Section 153Section 153CSection 254(1)Section 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

Lilaram, Mumbai vs. DCIT CC-4(2), Mumbai

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

ITA 5554/MUM/2025[2019-20]Status: DisposedITAT Mumbai12 Nov 2025AY 2019-20

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 132Section 153Section 153CSection 254(1)Section 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

Akhraj Pukhraj Chopra, Mumbai vs. DCIT CC-4(2), Mumbai

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

ITA 5553/MUM/2025[2019-20]Status: DisposedITAT Mumbai12 Nov 2025AY 2019-20

Bench: Shri Pawan Singh& Ms. Padmavathy S

Section 132Section 153Section 153CSection 254(1)Section 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

Van Bros Construction Pvt Ltd, Delhi vs. Assessment Unit, Income Tax Department

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

ITA 2381/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Nov 2025AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri M Balaganeshआ.अ.सं/.I.T.A No.2381/Del/2025 िनधा"रणवष"/Assessment Year:2019-20 बनाम Van Bros Construction Pvt. Ltd., Assessment Unit B-113, Lajpat Nagar-1, Vs. Income Tax Department, New Delhi. National Faceless Appeal, Pan No.Aaacv1092J Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 144BSection 147Section 148Section 148ASection 234ASection 234BSection 234D

support of his claim taken during the present appellate proceedings. As per the newly inserted proviso to section 251(1)(a) of the Act, Commissioner (Appeals) in case of order of assessment made u/s. 144 of the Act, may set aside such assessment and refer the case back ... said proviso to section 251(1)(a) of the Act 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; 6 VAN BROS

Shashi Bhalla, Lakhimpur Kheri vs. ITO Range-3(5), Lakhimpur Kheri

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

ITA 675/LKW/2024[2017-18]Status: DisposedITAT Lucknow11 Nov 2025AY 2017-18

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 142(1)Section 143(2)Section 143(3)Section 144Section 44ASection 69A

Officer, Ward- (5, Alappuzha* Annexure - E laddition under section 68 in respect of lunexplained cash credit found in assessee's| lbank - On appeal, Commissioner (Appeals) held Ithat since assessee did not maintain books of laccount, said unexplained deposits could not be} ltaxed under section 68 but under section 69A Whether ... Appeals) to set aside best judgement assessment. Finance Act 2024 6. The Finance Act, 2024 made significant changes to the powers of the Commissioner (Appeals) under Section 251 of the Income-tax Act. The existing Provisions of section 251 of the Act specify the powers of the Commissioner (Appeals). Further

Income Tax Officer, Ludhiana vs. Deep Trading Co., Ludhiana

The appeal of the Revenue is dismissed

ITA 477/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh11 Nov 2025AY 2012-13

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 477/Chd/2025 "नधा"रण वष" / Assessment Year : 2012-13 Income Tax Officer, Deep Trading Co., Room No. 228, First Floor, बनाम B 34-5503, Aaykar Bhawan, Rishi Nagar, 22 Footi Road, Vs. Ludhiana Haibowal Kalan, Ludhiana "थायी लेखा सं./ Pan No: Aahfd6122B अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : None राज"व क" ओर से/ Revenue By : Sh. Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 03.09.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 11.11.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Revenue Against The Order Dated 20.02.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Pertaining To A.Y. 2012-13. 2. Grounds Of Appeal Are As Under:

For Appellant: NoneFor Respondent: Sh. Manav Bansal, CIT DR
Section 144Section 251(1)Section 251(1)(a)

inserted by the Finance Act, 2024 w.e.f 1.10.2024, wherein, it is stipulated 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: [Provided that where

Income Tax Officer, Ward-11(1), Kol, Kolkata vs. Kish Engineering Pvt Ltd, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 1566/KOL/2025[2015-2016]Status: DisposedITAT Kolkata11 Nov 2025AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Income Tax Officer, Ward 11(1) Kolkata Kish Engineering Pvt. Ltd. Aayakar Bhawan P-7, 138Q, Pinic Garden Road, Chowringhee Road, 6 Th Floor, Kolkata-700039, Vs. Room No.6/20, Kolkata-700069, West Bengal West Bengal, (Appellant) (Respondent) Pan No. Aabck3454G Assessee By : Shri S.K. Tulsiyan & Ms. Lata Goyal, Ar Revenue By : Shri Dipu Koley, Dr Date Of Hearing: 28.10.2025 Date Of Pronouncement: 11.11.2025

For Appellant: Shri S.K. Tulsiyan &For Respondent: Shri Dipu Koley, DR
Section 68

Cash credit (Trade advance) - 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

Adhira Vinicom Private Limited, Howrah vs. Income Tax Officer, Ward (10)1, Kolkata

In the result, the appeal of the assessee is allowed

ITA 998/KOL/2024[2012-13]Status: DisposedITAT Kolkata11 Nov 2025AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Adhira Vincom Private Limited Ito, Ward (10)1, Kolkata 52/1, 2Nd Floor, Santan Mistry Chowringhee Square, Lane, Near Oriya Para Mandir, Vs. Kolkata-700069, West Bengal Howrah-711011, West Bengal (Appellant) (Respondent) Pan No. Aahca4935E Assessee By : Shri Devesh Poddar, Ar Revenue By : Shri Pankaj Pandey, Dr Date Of Hearing: 14.10.2025 Date Of Pronouncement: 11.11.2025

For Appellant: Shri Devesh Poddar, ARFor Respondent: Shri Pankaj Pandey, DR
Section 131Section 132Section 133(6)Section 143(2)Section 143(3)Section 153ASection 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

ACIT, Circle-3(1), Gurugram vs. Sunil Kumar, Gurugram

Appeal is dismissed

ITA 1/DEL/2025[2022-23]Status: DisposedITAT Delhi11 Nov 2025AY 2022-23

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 143(3)Section 41(1)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘A’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Sh. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1061/JPR/2025[2022-23]Status: DisposedITAT Jaipur10 Nov 2025AY 2022-23

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

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 ... imposition of penalty has been initiated, are completed, or six months from the end of the month in which the order of the Joint Commissioner (Appeals) or the Commissioner (Appeals) or as the case may be, the Appellate Tribunal is received by the Principal Commissioner or Commissioner, whichever period expires

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1060/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Nov 2025AY 2016-17

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

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 ... imposition of penalty has been initiated, are completed, or six months from the end of the month in which the order of the Joint Commissioner (Appeals) or the Commissioner (Appeals) or as the case may be, the Appellate Tribunal is received by the Principal Commissioner or Commissioner, whichever period expires

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Sh. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1059/JPR/2025[2016-17]Status: DisposedITAT Jaipur10 Nov 2025AY 2016-17

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

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 ... imposition of penalty has been initiated, are completed, or six months from the end of the month in which the order of the Joint Commissioner (Appeals) or the Commissioner (Appeals) or as the case may be, the Appellate Tribunal is received by the Principal Commissioner or Commissioner, whichever period expires

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Sh. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1058/JPR/2025[2012-13]Status: DisposedITAT Jaipur10 Nov 2025AY 2012-13

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

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 ... imposition of penalty has been initiated, are completed, or six months from the end of the month in which the order of the Joint Commissioner (Appeals) or the Commissioner (Appeals) or as the case may be, the Appellate Tribunal is received by the Principal Commissioner or Commissioner, whichever period expires

Dy. Commissioner of Income-Tax, Central Circle-2, Jaipur vs. Sh. Ashwani Gupta, Jaipur

In the result, all the appeals of the revenue are dismissed

ITA 1057/JPR/2025[2012-13]Status: DisposedITAT Jaipur10 Nov 2025AY 2012-13

Bench: Moving Towards The Facts Of The Case We Would Like To Mention That The Revenue Has Assailed The Appeal For Assessment Year 2012-13 In

For Appellant: Shri C.M. Agarwal, CAFor Respondent: Mrs. Alka Gautam, CIT
Section 269SSection 269TSection 271D

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 ... imposition of penalty has been initiated, are completed, or six months from the end of the month in which the order of the Joint Commissioner (Appeals) or the Commissioner (Appeals) or as the case may be, the Appellate Tribunal is received by the Principal Commissioner or Commissioner, whichever period expires

S H Kelkar and Company Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 4(3)(1), Mumbai

The appeal is partly allowed

ITA 5591/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Nov 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Shri Prabhash Shankar: A.Y : 2011-12

For Appellant: Shri Saurabh BhatFor Respondent: Shri Swapnil Choudhary
Section 140ASection 143(1)Section 143(3)Section 154Section 244ASection 4(2)

learned CIT(A) reads as under :- “4(2) Upon the filing the declaration, any appeal pending before the Income- tax Appellate Tribunal or Commissioner (Appeals), in respect of the disputed income or disputed interest or disputed penalty or disputed fee and tax arrear shall be deemed to have been withdrawn ... amount determined under Section 5(1). 14. Section 4(2) of the DTVSV Act prescribes that the appeal pending before the Tribunal or the Commissioner (Appeals) “in respect of the disputed income, disputed interest, disputed penalty or disputed fee and tax arrears” shall be deemed to have been withdrawn from

Bhavana Ritesh Shah, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

The appeal of the assessee is allowed for statistical purposes

ITA 5561/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Nov 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18

For Appellant: Shri Punit Jhabak, Ld. A.RFor Respondent: Shri Vikas Chandra, Ld. Sr. D.R
Section 144BSection 147Section 250

reply or documentary evidence, as called for. 4. Admittedly such details were not submitted before the Assessing Officer but filed before the Ld. Commissioner (Appeals). The Ld. Commissioner, after considering the reply given to Column No. 12 of Form No. 35-regarding whether any documentary evidence other than those produced

Salimahmed Umarganibhai Vahora, Vadodara vs. The ITO, Ward-1(3)(1), Vadodara

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

ITA 1595/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad07 Nov 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalsalimahmed Umarganibhai The Income Tax Officer, Vs. Vahora, Ward-1(3)(1), Vahorawad Bazar, Vadodara. Nr. Nagar Palika, Padra, Vadodara-391440. [Pan :Ajbpv8394 C] (Appellant) .. (Respondent) Appellant By : Shri M K Patel, Ar Respondent By: Shri Ravindra, Sr. Dr Date Of Hearing 04.11.2025 Date Of Pronouncement 07.11.2025

For Appellant: Shri M K Patel, ARFor Respondent: Shri Ravindra, Sr. DR
Section 234ASection 250(6)Section 271ASection 69A

additions made by the Assessing Officer ex-parte in violation of the mandate under section 250(6) of the Act, which requires the Commissioner (Appeals) to dispose of the appeal through a reasoned order on each ground of appeal, irrespective of the appellant's absence or non-compliance ... learned Commissioner of Income Tax (Appeals), NFAC failed to appreciate that non-appearance of the appellant does not empower the Commissioner (Appeals) to dismiss or decide appeal on merits without real hearing. 5.0 The learned Commissioner of Income Tax (Appeals), NFAC has erred in law and on facts in confirming