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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)

Neel Kumar Ajmera, Indore vs. The A.C.I.T 4 (1), Indore

Appeal is allowed for statistical purpose

ITA 234/IND/2024[2008-09]Status: DisposedITAT Indore22 Sept 2025AY 2008-09

Bench: Shri B.M. Biyani

Section 132Section 153ASection 254

appeal is dismissed.” 5. Ld. AR thereafter submitted that the section 250(6) of the Income-tax Act, 1961 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

Lilavantiben Gordhanbhai Padariya, Rajkot vs. ITO, Ward 1(1)(3), Rajkot

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 372/RJT/2023[2013-14]Status: DisposedITAT Rajkot19 Sept 2025AY 2013-14

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 372/Rjt/ 2023 ("नधा"रणवष" / Assessment Year: (2013-14) Lilavantiben Gordhanbhai Padariya Vs. Ito, Wd – 1(1)(3), Rajkot Vrajdham, Shardanagar Main Road, Aayakar Bhavan, Race Course Mabdi Road, Rajkot – 360001 Ring Road, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acgpp7067E (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld.Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 24/06/2025 Date Of Pronouncement : 19/09/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee Is Directed Against The Order Passed By The National Faceless Appeal Centre [(In Short “Nfac/Ld. Cit(A)”] Vide Order Dated 09.09.2023, Which In Turn Assessment Order Passed By Assessment Unit, Income Tax Department / Assessing Officer Under Section 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 04.12.2017. 2. Grounds Of The Appeal Raised By The Assessee Are As Follows: 1. The Learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi Erred In Upholding Validity Of Assessment U/S 147 By Issue Of Notice U/S 148 Of The Act. 2 The Learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi Erred In Confirming Action Of Assessing Officer In Making Addition Of Rs. 1,11,13,196/- By Way Of Alleged Difference Between Sales As Per Annual Vat Return & Sales As Per Audited Accounts By Failing To Appreciate That The Alleged Difference Was Duly Reconciled & Explained.

For Appellant: Shri D. M. Rindani, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 139Section 143(3)Section 147Section 148Section 44A

short “the Act”), vide order dated 04.12.2017. 2. Grounds of the appeal raised by the assessee are as follows: 1. The learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi erred in upholding validity of assessment u/s 147 by issue of notice u/s 148 of the Act. 2 The learned Commissioner ... sales as per audited accounts by failing to appreciate that the alleged difference was duly reconciled and explained. Lilavantiben Gordhanbhai Padariya 3 The learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi failed to appreciate that excise duty was not payable at the year-end but was receivable in the balance

Pushpanjali Constructions Private Limited, Pushpanjali Palace, Dehli Gate, Agra vs. DCIT, Cen Cir Ghaziabad

In the result appeal filed by the assessee is partly allowed

ITA 1001/DEL/2025[2012-13]Status: DisposedITAT Delhi19 Sept 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Sudhir Kumar

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Ms. Amisha S. Gupt, CITDR
Section 143(3)Section 153ASection 153CSection 153DSection 69C

against him in view of provisions of section 132(4A) and made addition on account of entries recorded in said two diaries - On appeal, Commissioner (Appeals) deleted addition - On revenue's appeal, Tribunal held that provisions contained in section 132(4A) did not authorize Assessing Officer to raise such ... diaries had materialized into transactions giving rise to income which had not been disclosed in regular books of account - Tribunal, therefore, upheld order of Commissioner (Appeals) - Whether findings of facts recorded by Tribunal could be interfered with - Held, no” Ashwani Kumar v. ITO 39 ITD 183 (Delhi)-“Section 694A, read

ITO, New Delhi vs. M/S North West Sales and Marketing P. Ltd., New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 2984/DEL/2017[2011-12]Status: DisposedITAT Delhi19 Sept 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Gaurav Jain, AdvocateFor Respondent: Ms.Monika Singh, CIT-DR
Section 68

regards, admission of additional evidences, we have noted the following provisions of Rule 46A:- 6[7Production of additional evidence before the 8[8a[Joint “… Commissioner] (Appeals)] 9[and Commissioner (Appeals)]. Page 3 of 12 46A. (1) The appellant shall not be entitled to produce before the 8[8a[Joint Commissioner ... Appeals)] 9[or, as the case may be, the Commissioner (Appeals)], any evidence, whether oral or documentary, other than the evidence produced by him during the course of proceedings before the 10[Assessing Officer], except in the following circumstances, namely :— (a) where the 10[Assessing Officer] has refused to admit

Rajesh Kumar, Patna vs. ITO, Ward- 3 (2), Gaya

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 171/PAT/2025[2018-19]Status: DisposedITAT Patna18 Sept 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 147Section 234ASection 250Section 271FSection 69A

reason for arriving at such decision. The provisions of section 250(6) are reproduced as under: “250(6) – The order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision ... taxmann.com 348 (Madras) it has been held that a speaking order on merits with reasons and findings is to be passed by Commissioner (Appeals) on basis of ground raised in assessee's appeal; he cannot dispose assessee's appeal merely by holding that Assessing Officer's order is a self

Narayanbhai Shivabhai Patel, Mehsana vs. The ITO, Ward-1, Mehsana

In the result, the appeal of the assessee is allowed

ITA 1357/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad18 Sept 2025AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2020-21

Section 143(3)Section 270ASection 270A(6)Section 270A(6)(a)Section 270A(6)(b)Section 56(2)(x)

amount of income in respect of which the assessee offers an explanation and the Assessing Officer or 95[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 and the assessee ... basis of an estimate, if the accounts are correct and complete to the satisfaction of the Assessing Officer or 95[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 the income cannot

Shri Nityanand Pandey, Hooghly vs. I.T.O., Ward - 23(1), Hooghly

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2067/KOL/2024[2013-2014]Status: DisposedITAT Kolkata18 Sept 2025AY 2013-2014

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 148Section 148(2)Section 250

reason for arriving at such decision. The provisions of section 250(6) are reproduced as under: “250(6) – The order of the Commissioner (Appeals) disposing of the appeal shall be in writing and shall state the points for determination, the decision thereon and the reason for the decision ... taxmann.com 348 (Madras) it has been held that a speaking order on merits with reasons and findings is to be passed by Commissioner (Appeals) on basis of ground raised in assessee's appeal; he cannot dispose assessee's appeal merely by holding that Assessing Officer's order is a self

Nmd Constructions LLP, Bhilwara vs. ITO, Ward-1, Bhilwara

In the result, based on above the appeal of the assessee is allowed

ITA 547/JPR/2025[2020-21]Status: DisposedITAT Jaipur17 Sept 2025AY 2020-21

Bench: Shri Gagan Goyal & Shri Narinder Kumarnmd Constructions Llp, C/O. Garg Petroleum Near Railway Phatak, Bhilwara 311 001 Pan No. Aanfn 8731C ...... Appellant Vs. Acit, Central Circle-01, Ajmer …...Respondent

For Appellant: Mr. B. P. Mundra, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Ld. Sr. DR
Section 131Section 132Section 132ASection 132oSection 133ASection 250Section 292C

contained in or revealed by such document would have to be examined to link such document to undisclosed income of the assessee. Both the Commissioner (Appeals) and the Tribunal found no linking factor. Both these authorities rejected the reasoning of the Assessing Officer on this basis of which the latter

Murli Dhar Upadhyay, Jaipur vs. ITO Ward 6(3), Jpr, Jaipur

In the result, stands allowed

ITA 252/JPR/2025[2017-18]Status: DisposedITAT Jaipur16 Sept 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Ashok Kumar Gupta, AdvFor Respondent: Shri Gautam Singh Choudhary, JCIT a
Section 143(2)Section 143(3)Section 270A(1)Section 40A(3)

dispute about the genuineness of the transactions and the payment and identity of the receiver were established. The conclusion reached by the Commissioner (Appeals) was correct and the Tribunal by ignoring the scope of clause(j)ofrule6DDasexplainedbytheBoard’sCircularhad erred in reversing the finding reached by the Commissioner (Appeals). The addition

Lakhmi Chand Khushiramani, Gwalior vs. Income Tax Officer, Ward 1(1), Gwalior

ITA 284/AGR/2025[2017-18]Status: DisposedITAT Agra15 Sept 2025AY 2017-18
Section 139Section 142(1)Section 144Section 249(4)Section 249(4)(b)Section 294(4)(b)Section 69A

ITA No.-284/Agr/2025 Lakhmi Chand Khushiramani Assessment Order u/s 144 of the Income-tax Act, 1961(hereinafter referred to

Income Tax Officer Ward-1(1), Jaipur vs. Kiran Infra Ispat Limited, Jaipur

ITA 535/JPR/2025[2013-14]Status: DisposedITAT Jaipur15 Sept 2025AY 2013-14
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri. Rajesh Ojha, CIT-DR
Section 143(3)Section 147Section 148Section 149Section 68

question was received - Further, turnover of assessee was also not disputed by Assessing Officer - Whether since all these invoices were part of total sales, Commissioner (Appeals) was not justified in sustaining additions made by Assessing officer and thus, addition was to be deleted Held, yes [Para 13] [In favour ... Section 37(1) of the Income-tax Act, 1961 - Business expenditure - Allowability of (Bogus purchase) - Certain portion of purchases made by assessee was disallowed Commissioner (Appeals) found that entire disallowance was based on third party information gathered by Investigation Wing of Department, which had not been independently subjected to further

Sh. Mahendra Kumar Goyal, Sikar vs. ACIT, Central Circle-3, Jaipur

In the result of the appeal of the assessee are disposed off as under

ITA 500/JPR/2025[2015-16]Status: DisposedITAT Jaipur15 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

limiting the time within which any action for assessment, reassessment or recomputation may be taken. Section 251 reads as follows : Powers of the70[Joint Commissioner (Appeals) or the] Commissioner (Appeals). 251. (1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers— (a) in an appeal against ... other case, he may pass such orders in the appeal as he thinks fit. 70[(1A) In disposing of an appeal, the Joint Commissioner (Appeals) shall have the following powers— (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment

Sh. Mahendra Kumar Goyal, Sikar vs. ACIT, Central Circle-3, Jaipur

In the result of the appeal of the assessee are disposed off as under

ITA 497/JPR/2025[2019-20]Status: DisposedITAT Jaipur15 Sept 2025AY 2019-20

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, आंकड़ुठरधारी आइटीएए सं.र@ITA Nos.493, 495 to 498, 500/JP/2025 निर्धारण वर्ष@Assessment Years : 2014-15 to 2016-17, 2018-19 to 2020-21 Mahendra Kumar Goyal चुके Vs. ACIT/DCIT Ward No. 2, Shahpura Road Neem Ka Thana, Sikar Central Circle-03, Jaipur लेखा संख्याल्लेय सं.जीआइआर सं.पान@PAN/GIR No.: ACFPG0306G अपीलार्थी@Appellant प्रत्यार्थी@Respondent निर्धारीती की आर से@ Assessee by : Shri P. C. Parwal, CA राजस्व की आर से@ R

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

limiting the time within which any action for assessment, reassessment or recomputation may be taken. Section 251 reads as follows : Powers of the70[Joint Commissioner (Appeals) or the] Commissioner (Appeals). 251. (1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers— (a) in an appeal against ... other case, he may pass such orders in the appeal as he thinks fit. 70[(1A) In disposing of an appeal, the Joint Commissioner (Appeals) shall have the following powers— (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment

Sh. Mahendra Kumar Goyal, Sikar vs. ACIT, Central Circle-3, Jaipur

In the result of the appeal of the assessee are disposed off as under

ITA 496/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Sept 2025AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

limiting the time within which any action for assessment, reassessment or recomputation may be taken. Section 251 reads as follows : Powers of the70[Joint Commissioner (Appeals) or the] Commissioner (Appeals). 251. (1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers— (a) in an appeal against ... other case, he may pass such orders in the appeal as he thinks fit. 70[(1A) In disposing of an appeal, the Joint Commissioner (Appeals) shall have the following powers— (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment

Sh. Mahendra Kumar Goyal, Sikar vs. ACIT, Central Circle-3, Jaipur

In the result of the appeal of the assessee are disposed off as under

ITA 493/JPR/2025[2014-15]Status: DisposedITAT Jaipur15 Sept 2025AY 2014-15

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri P. C. Parwal, CAFor Respondent: Mrs. Anita Rinesh, JCIT, Sr. DR
Section 127Section 143(2)Section 143(3)Section 153ASection 69

limiting the time within which any action for assessment, reassessment or recomputation may be taken. Section 251 reads as follows : Powers of the70[Joint Commissioner (Appeals) or the] Commissioner (Appeals). 251. (1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers— (a) in an appeal against ... other case, he may pass such orders in the appeal as he thinks fit. 70[(1A) In disposing of an appeal, the Joint Commissioner (Appeals) shall have the following powers— (a) in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment

Income Tax Officer Ward 1 Fatehabad, Fatehabad vs. Rakesh Nagpal, Fatehabad

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

ITA 60/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh15 Sept 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 59 & 60/Chd/2025 "नधा"रण वष" / Assessment Year: 2018-19 The Ito, Shri Rakesh Nagpal, Ward – 1, Vs House No. 39A, Model Town, Fatehabad. Fatehabad. "थायी लेखा सं./Pan No: Aalpn1386K अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Suraj Bhan Nain, Advocate Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 11.09.2025 Date Of Pronouncement : 15.09.2025 Hybrid Hearing O R D E R Per Rajpal Yadav, Vp

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR
Section 143(3)Section 144Section 144BSection 251(1)Section 251(1)(a)Section 270A(2)

take note of relevant part of Section 251(1)(a) of the Income Tax Act, which reads as under : “Powers of the Joint Commissioner (Appeals) or the Commissioner (Appeals) 251.(1) In disposing of an appeal, the Commissioner (Appeals)shall have the following powers- ITA Nos.59 & 60/CHD/2025 A.Y.2018-19

Income Tax Officer Ward 1 Fatehabad, Fatehabad vs. Rakesh Nagpal, Fatehabad

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

ITA 59/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh15 Sept 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwalआयकर अपील सं./ Ita Nos. 59 & 60/Chd/2025 "नधा"रण वष" / Assessment Year: 2018-19 The Ito, Shri Rakesh Nagpal, Ward – 1, Vs House No. 39A, Model Town, Fatehabad. Fatehabad. "थायी लेखा सं./Pan No: Aalpn1386K अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Suraj Bhan Nain, Advocate Revenue By : Dr. Ranjit Kaur, Addl. Cit Sr.Dr Date Of Hearing : 11.09.2025 Date Of Pronouncement : 15.09.2025 Hybrid Hearing O R D E R Per Rajpal Yadav, Vp

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR
Section 143(3)Section 144Section 144BSection 251(1)Section 251(1)(a)Section 270A(2)

take note of relevant part of Section 251(1)(a) of the Income Tax Act, which reads as under : “Powers of the Joint Commissioner (Appeals) or the Commissioner (Appeals) 251.(1) In disposing of an appeal, the Commissioner (Appeals)shall have the following powers- ITA Nos.59 & 60/CHD/2025 A.Y.2018-19

Income Tax Officer, Ludhiana vs. Rajesh Gupta Prop. M/S Shri Balaji Trading Co., Ludhiana

In the result, appeal of the Revenue is dismissed

ITA 459/CHANDI/2025[2017]Status: DisposedITAT Chandigarh15 Sept 2025

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Tej Mohan Singh, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT Sr.DR
Section 144Section 251(1)

take note of the relevant part of Section 251(1) of the Income Tax Act, 1961, which reads as under : Powers of the Joint Commissioner (Appeals) or the Commissioner (Appeals) 251.(1) In disposing of an appeal, the Commissioner (Appeals)shall have the following powers- (a) in an appeal against

Rng Construction Co, Mandideep vs. Addl., Jt., Dy., Asstt.ITO, Bhopal

ITA 230/IND/2024[2015-16]Status: DisposedITAT Indore12 Sept 2025AY 2015-16

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

Section 139Section 143(3)Section 147Section 148Section 36(1)(va)Section 40Section 43B

expenses for the assessment year 1986-87. The assessed preferred an appeal against the order of re-assessment dated 24th September 1990, whereupon the Commissioner (Appeals) by an order dated 23rd August 1991 quashed the re-assessment proceedings holding that the assessed had disclosed all the facts. It was held

Rain Cements, Hyderabad vs. DCIT., Circle-3(1), Hyderabad

In the result, appeal of the Assessee is dismissed

ITA 540/HYD/2025[2015-16]Status: DisposedITAT Hyderabad12 Sept 2025AY 2015-16

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Sri Deepak Chopra, AdvocateFor Respondent: Sri Madan Mohan Meena, Sr. AR
Section 115Section 115JSection 143(1)Section 234CSection 246A

delay only with reference to the affidavit of Shri M.L.S. Rao, Director of the company. In the said affidavit Mr. Rao stated that the Commissioner (Appeals)'s order was misplaced and forgotten. It was found while sorting out the unwanted papers. Thereafter steps were taken for the preparation