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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)

Kamal Nagari Sahakari Patsanstha Ltd., Raigad vs. ITO Ward-3, Panvel

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

ITA 390/PUN/2025[2013-14]Status: DisposedITAT Pune26 Aug 2025AY 2013-14

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Ajinkya VaishampayanFor Respondent: Shri Ramnath P Murkunde
Section 143(3)Section 144Section 148Section 148ASection 149(1)(b)Section 56Section 57Section 80P(2)(a)Section 80P(2)(d)

appellant's) side has not been heard and examined. 5.5 The section 251(1)(a) of the Income Tax Act, enumerating powers of the Commissioner (Appeals) and Joint Commissioner (Appeals), has been modified w.e.f. 1/10/2024 by the introduction of the Proviso, which states: 1. In disposing of an appeal ... 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 such appeal is against an order of assessment made under section 144, he may set aside the assessment and refer the case

Marathwada Association of Small Scale Indutries & Agriculture, Pune vs. CIT(A), Addl/JCIT(A)1, Gurugram

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

ITA 1077/PUN/2025[2014-15]Status: DisposedITAT Pune26 Aug 2025AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Ms. Shubhada L JoshiFor Respondent: Shri Ramnath P Murkunde
Section 11Section 12ASection 12A(1)(b)Section 139Section 143(1)

audit report could not be filed by the assessee-trust before Assessing Officer due to reason beyond control but it was filed belatedly before Commissioner (Appeals) during appellate stage in prescribed Form No.10B as was required under section 12A(1)(b), the claim of exemption under section

Starpoint Vinimay Private Limited, Kolkata vs. Asst Commissioner of Income Tax (OSD) Ward-1(1), Kolkata

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

ITA 340/KOL/2025[2015-2016]Status: DisposedITAT Kolkata26 Aug 2025AY 2015-2016

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 143(3)Section 250Section 5

this respect, it is relevant to examine the provisions of section 250(6) which 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 the assessee's appeal merely by holding that Assessing Officer's order

Veeranan Srinivasan, K.K.Nagar, Madurai vs. Deputy Commissioner of Income Tax, Non Corporate Circle-1, Madurai, Income Tax Office

ITA 1136/CHNY/2025[2017-2018]Status: DisposedITAT Chennai26 Aug 2025AY 2017-2018

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1136/Chny/2025

Section 115BSection 132Section 143(3)Section 154Section 69B

notice by the assessee 24[or by the deductor] 22[or by the collector], and where the authority concerned is [the Joint Commissioner (Appeals) or] the 22[***] 28[Commissioner (Appeals)], by the 2[Assessing] Officer also. (3) An amendment, which has the effect of enhancing an assessment 2 or reducing ... such amendment for rectifying any such mistake which has been brought to its notice by the assessee, and where the authority concerned is the [Commissioner (Appeals)], by the [Assessing] Officer also." 9.0 Thus, it is seen that section 154 of the Act mainly provides authority to the assessing officer

Arti Shailen Topiwala, Andheri West, Mumbai vs. ITO, Ward 34(1)(1), Mumbai, Bkc, Bandra East

In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for statisti...

ITA 4384/MUM/2025[2013-2014]Status: DisposedITAT Mumbai26 Aug 2025AY 2013-2014

Bench: Shri Sandeep Gosain () & Om Prakash Kant () Ita No. 4383 & 4384/Mum/2025 Assessment Year: 2013-14 Arti Shailen Topiwala Ito, Ward 34(1)(1), Mumbai B-701, Parimal Apartment, C.D. Income Tax Appellate Barfiwala Road, Andheri West, Vs. Tribunal, Mumbai- 400058 Mumbai- 400020 Pan No. Aacpt 3505 D Appellant Respondent

For Appellant: Mr. Rajesh ShahFor Respondent: Mr. Surendra Mohan –SR. DR
Section 271Section 271(1)(b)

rectify the lapse. We accordingly set aside the to the assessee to rectify the lapse. We accordingly set aside the order of the Commissioner (Appeals) and remit the matter to his file. order of the Commissioner (Appeals) and remit the matter to his file. order of the Commissioner (Appeals ... delayed by a period of 2673 days. Ld. CIT(A) holding the same to be delayed by a period of 2673 days. The Commissioner (Appeals), however, rejected the plea, holding The Commissioner (Appeals), however, rejected the plea, holding The Commissioner (Appeals), however, rejected the plea, holding that the delay

Arti Shailen Topiwala, Andheri West, Mumbai vs. ITO, Ward 34(1)(1), Mumbai, Bkc, Bandra East

In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for In the result both the appeals of the assessee are allowed for statisti...

ITA 4383/MUM/2025[2013-2014]Status: DisposedITAT Mumbai26 Aug 2025AY 2013-2014

Bench: Shri Sandeep Gosain () & Om Prakash Kant () Ita No. 4383 & 4384/Mum/2025 Assessment Year: 2013-14 Arti Shailen Topiwala Ito, Ward 34(1)(1), Mumbai B-701, Parimal Apartment, C.D. Income Tax Appellate Barfiwala Road, Andheri West, Vs. Tribunal, Mumbai- 400058 Mumbai- 400020 Pan No. Aacpt 3505 D Appellant Respondent

For Appellant: Mr. Rajesh ShahFor Respondent: Mr. Surendra Mohan –SR. DR
Section 271Section 271(1)(b)

rectify the lapse. We accordingly set aside the to the assessee to rectify the lapse. We accordingly set aside the order of the Commissioner (Appeals) and remit the matter to his file. order of the Commissioner (Appeals) and remit the matter to his file. order of the Commissioner (Appeals ... delayed by a period of 2673 days. Ld. CIT(A) holding the same to be delayed by a period of 2673 days. The Commissioner (Appeals), however, rejected the plea, holding The Commissioner (Appeals), however, rejected the plea, holding The Commissioner (Appeals), however, rejected the plea, holding that the delay

M/S. International Specialty Products (India) Private Limited, Hyderabad vs. Circle 15(1)(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 3255/MUM/2025[2012-13]Status: DisposedITAT Mumbai26 Aug 2025AY 2012-13

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri P.V.S.S. Prasad, CAFor Respondent: Shri Virabhadra S. Mahajan, Sr. DR
Section 271Section 271(1)(c)Section 92C

particulars have been concealed or inaccurate particulars have been furnished, unless the assessee proves to the satisfaction of the Assessing Officer or the Joint Commissioner (Appeals) or) the Commissioner (Appeals) or the Principal Commissioner or Commissioner that the price charged or paid in such transaction was computed in accordance with

Vimal Sureshbhai Mishra, Ahmedabad vs. Central Processing Unit, Bangaluru, Present Jurisi. the ITO, Ward-5(3)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1043/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad25 Aug 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: NoneFor Respondent: Shri Prateek Sharma, Sr. DR
Section 139Section 140ASection 143(1)Section 154Section 234BSection 234B(1)

correct the mistake apparent from the record, but the same was rejected vide order dated 14.02.2025. 4. In appeal before the Commissioner (Appeals), the appellant submitted that interest under section 234B of the Act should have been computed only from 1st April of the assessment year up to the date

Varun Trade Link Private Limited, Kolkata vs. CIT(Appeals), NFAC, Delhi

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

ITA 401/KOL/2025[2014-15]Status: DisposedITAT Kolkata25 Aug 2025AY 2014-15

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 147Section 148Section 249(4)(b)Section 250Section 68

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

M.P. Santhosh Kumar, ITO, Chennai vs. Greenpeace Environment Trust, Chennai

In the result, appeal filed by the Revenue stands dismissed

ITA 406/CHNY/2025[2011]Status: DisposedITAT Chennai25 Aug 2025

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 406/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2011-12 Income Tax Officer, Greenpeace Environment Trust, Exemptions, Ward-1, Vs. New No.49, Old No.23, Chennai. Ellaiamman Colony, Gopalapuram, Chennai-600 086. [Pan:Aaatg-3538-R] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Mr. Kumar Chandan, Jcit. प्रत्यथी की ओर से/Respondent By : Shri. Y.Sridhar, F.C.A. सुनवाई की तारीख/Date Of Hearing : 19.06.2025 घोर्णा की तारीख/Date Of Pronouncement : 25.08.2025 आदेश /O R D E R Per S. R. Raghunatha, Am :

For Appellant: Mr. Kumar Chandan, JCITFor Respondent: Shri. Y.Sridhar, F.C.A
Section 11Section 12ASection 13(1)(c)Section 13(3)(c)Section 143(1)Section 143(3)

such advancement of loans was in violation of the provisions of section 13(1)(d) read with section 11(5) of the Act. The Commissioner (Appeals) held that advancement of interest-free loans to other charitable organisations which were registered under section 12A or 12AA was outside the purview ... assessee-trust in terms of section 11(1)(a) of the Act in the computation of taxable income and this was confirmed by the Commissioner (Appeals). On appeal by the assessee : Held, allowing the appeal, that depreciation could be claimed as application of income while computing the income that

Assistant Commissioner of Income Tax, Jalandhar vs. M/S Jasdeep Kaur Chadha, Jalandhar

In the result, the appeal of the assessee is allowed and the revenue appeal is dismissed

ITA 359/ASR/2025[2018-19]Status: DisposedITAT Amritsar22 Aug 2025AY 2018-19

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

Section 143(3)Section 68

assessee - On that basis, Assessing Officer made addition of Rs. 1.50 lakhs to assessee's income by invoking provisions of section 68 - On appeal, Commissioner (Appeals) sustained addition - However, on second appeal, Tribunal, on basis of material on record, came to conclusion that amount in question had been repaid

Jasdeep Kaur Chadha-Jalandhar, Punjab vs. Jao the DCIT Circle-4 Jalandhar, Punjab

In the result, the appeal of the assessee is allowed and the revenue appeal is dismissed

ITA 250/ASR/2025[2018-2019]Status: DisposedITAT Amritsar22 Aug 2025AY 2018-2019

Bench: Sh. Udayan Das Gupta & Sh. Khettra Mohan Roy

Section 143(3)Section 68

assessee - On that basis, Assessing Officer made addition of Rs. 1.50 lakhs to assessee's income by invoking provisions of section 68 - On appeal, Commissioner (Appeals) sustained addition - However, on second appeal, Tribunal, on basis of material on record, came to conclusion that amount in question had been repaid

Akhilesh Kumar Patel, Shahdol vs. Income Tax Officer Dhar, Dhar

ITA 627/IND/2024[2018-19]Status: DisposedITAT Indore22 Aug 2025AY 2018-19

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

Section 147

आयकर अपीलीय अधिकरण, इंदौर न्यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT

M/S. Abheek Dealtrade Private Limited, Kolkata vs. ITO, Ward 4(3), Kolkata

Appeal of the assessee is dismissed

ITA 232/KOL/2025[2012-13]Status: DisposedITAT Kolkata22 Aug 2025AY 2012-13

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 144Section 147Section 153(3)Section 250Section 251(1)(a)Section 69A

Income Tax Act wef 01/10/2024 provides that in the case of appeal against an order of assessment made under section 144, the Commissioner (Appeals) is empowered to set aside the order of assessment and refer the matter back to the Assessing officer for making a fresh assessment. 7.2 In view

Mondelez India Foods Pvt. Ltd. (Formerly Known As Cadbury India Ltd.), Mumbai vs. ACIT, Range 5 (1)(2), Mumbai

In the result, appeal of the assessee company is allowed/partly

ITA 7269/MUM/2019[2015-16]Status: DisposedITAT Mumbai22 Aug 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.7269/Mum/2019 निर्धारण वर्ष / Assessment Year :2015-16 M/S Mondelez India Foods Private Limited (Formerly Known As Cadbury India Limited), Mondelez House, Unit No.2001, 20Th Floor Tower-3 (Wing C) India Bulls Finance Centre), Parel, Mumbai-400 013 Pan : Aaac0460H ........अपीलार्थी / Appellant बनाम / V/S. The Assistant Commissioner Of Income-Tax, Range-5(1)(2), Mumbai, Aayakar Bhavan, M.K. Road Mumbai-400 020 ......प्रत्यर्थी / Respondent Assessee By : Shri J.D. Mistri, Sr. Advocate Shri Hiten Chande Revenue By : Shri Pankaj Kumar, Cit-Dr सुनवाई की तारीख / Date Of Hearing :18.08.2025 घोषणा की तारीख / Date Of Pronouncement : 22.08.2025

For Appellant: Shri J.D. Mistri, Sr. AdvocateFor Respondent: Shri Pankaj Kumar, CIT-DR
Section 115JSection 143(3)Section 144C(1)Section 144C(5)Section 14ASection 234C

assessee had assumed that a benefit has accrued to the overseas A.E. on account of AMP expenditure incurred by the assessee. The learned Commissioner (Appeals) has upheld the adjustment / addition proposed by the Transfer Pricing Officer simply relying upon his order passed in assessee's own case for assessment year ... fortrademark. In this context, the Transfer Pricing Officer has also referred tosimilar dispute arising in the preceding assessment years. It is evident thatthe learned Commissioner (Appeals) has upheld the disallowance of royaltypayment of trademark simply relying upon the order passed by him inassessee's own case for assessment year

ACIT, Circle-26(2), New Delhi vs. Vikram Electric Equipment P.Ltd, New Delhi

ITA 4651/DEL/2018[2009-10]Status: DisposedITAT Delhi22 Aug 2025AY 2009-10

Bench: Shir Mahavir Singh() Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 143(1)Section 143(3)Section 147Section 148Section 68

invalid due to non-service of notice under Section 148 of the Act. Accordingly we uphold the order of learned Commissioner (Appeals) by dismissing the ground raised." 26. Similarly in the case of Shri Sanjeev Chandrakant Deo Vs. ITO in ITA Nos.2280 & 2281/Mum/2019 dated 25/10/2021 the Mumbai Bench

India Construction, Diamond Harbour vs. ITO, Ward - 25(1), Kolkata

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

ITA 2592/KOL/2024[2018-19]Status: DisposedITAT Kolkata21 Aug 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133(6)Section 143(3)Section 250

this respect, it is relevant to examine the provisions of section 250(6) which 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 the assessee's appeal merely by holding that Assessing Officer's I.T.A. No.: 2592/KOL/2024

Kmv Projects Limited, Hyderabad vs. DCIT-CC-1(3), Hyderabad

In the result, ITA Nos.905 & 906/Bang/2025 are allowed for statistical purposes and ITA No

ITA 906/BANG/2025[2016-17]Status: DisposedITAT Bangalore21 Aug 2025AY 2016-17

Bench: Shri Dipak P. Ripote & Shri Prakash Chand Yadavassessment Year: 2018-19

For Appellant: Mr. Mohd. Afzal, A.RFor Respondent: Sri Shivanand H Kalakeri, D.R
Section 143(3)Section 246ASection 250Section 251(1)

Sections 250 and251 of the Act respectively. The relevant provisions for consideration are as under:— 'Procedure in appeal 250 (1) . . . . . . . . . . . . . (2) . . . . . . . . . . . . . . . . . (3) . . . . . . . . . . . . . . . . . . (4) The Commissioner (Appeals) may, before disposing of any appeal, make such further inquiry as he thinks fit, or may direct the Assessing Officer to make further inquiry ... report the result of the same to the Commissioner (Appeals). (5) . . . . . . . . . . . . . . . . . . (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. (6A) . . . . . . . . . . . . . . . . . . (7) . . . . . . . . . . . . . . . . . . Powers of the Commissioner (Appeals) "Section

Kmv Projects Limited, Hyderabad vs. DCIT-CC-1(3), Hyderabad

In the result, ITA Nos.905 & 906/Bang/2025 are allowed for statistical purposes and ITA No

ITA 905/BANG/2025[2015-16]Status: DisposedITAT Bangalore21 Aug 2025AY 2015-16

Bench: Shri Dipak P. Ripote & Shri Prakash Chand Yadavassessment Year: 2018-19

For Appellant: Mr. Mohd. Afzal, A.RFor Respondent: Sri Shivanand H Kalakeri, D.R
Section 143(3)Section 246ASection 250Section 251(1)

Sections 250 and251 of the Act respectively. The relevant provisions for consideration are as under:— 'Procedure in appeal 250 (1) . . . . . . . . . . . . . (2) . . . . . . . . . . . . . . . . . (3) . . . . . . . . . . . . . . . . . . (4) The Commissioner (Appeals) may, before disposing of any appeal, make such further inquiry as he thinks fit, or may direct the Assessing Officer to make further inquiry ... report the result of the same to the Commissioner (Appeals). (5) . . . . . . . . . . . . . . . . . . (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. (6A) . . . . . . . . . . . . . . . . . . (7) . . . . . . . . . . . . . . . . . . Powers of the Commissioner (Appeals) "Section

Kmv Projects Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-2(4), Bengaluru

In the result, ITA Nos.905 & 906/Bang/2025 are allowed for statistical purposes and ITA No

ITA 783/BANG/2025[2018-19]Status: DisposedITAT Bangalore21 Aug 2025AY 2018-19

Bench: Shri Dipak P. Ripote & Shri Prakash Chand Yadavassessment Year: 2018-19

For Appellant: Mr. Mohd. Afzal, A.RFor Respondent: Sri Shivanand H Kalakeri, D.R
Section 143(3)Section 246ASection 250Section 251(1)

Sections 250 and251 of the Act respectively. The relevant provisions for consideration are as under:— 'Procedure in appeal 250 (1) . . . . . . . . . . . . . (2) . . . . . . . . . . . . . . . . . (3) . . . . . . . . . . . . . . . . . . (4) The Commissioner (Appeals) may, before disposing of any appeal, make such further inquiry as he thinks fit, or may direct the Assessing Officer to make further inquiry ... report the result of the same to the Commissioner (Appeals). (5) . . . . . . . . . . . . . . . . . . (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. (6A) . . . . . . . . . . . . . . . . . . (7) . . . . . . . . . . . . . . . . . . Powers of the Commissioner (Appeals) "Section