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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)

Eight Roads Investment Advisors Private Limited, Mumbai vs. Assistant Director of Income Tax, Centralized Processing Centre, Bengaluru

In the result, appeal of the assessee is allowed, as per our aforesaid

ITA 2928/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Aug 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.2928/Mum/2025 "नधा"रण वष" / Assessment Year :2020-21 Eight Roads Investment Advisors Private Limited 16Th Floor, Plot No.82, Avighna House, Dr. Annie Besant Road, Worli, Mumbai-400 018 Pan: Aabcf1370N ........अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax/Cpc, Bengaluru ……""यथ" / Respondent

For Appellant: Ms.Chandari Shah a/wFor Respondent: Shri Himanshu Joshi, Sr. DR
Section 143(3)Section 154Section 250Section 36(1)(va)

notice by the assessee, and where the authority concerned is the [* * *] [ Certain words omitted by Act 21 of 1998, Section 65 (w.e.f. 1.10.1998).] [Commissioner (Appeals)] [ Inserted by Act 29 of 1977, Section 29 (w.e.f. 10.7.1978).], by the [Assessing Officer] [ Substituted by Act 4 of 1988, Section 2, for " Income

Ajay Kumar, Hajipur vs. ITO Ward 1(3), Hajipur

In the result, the appeal filed by the assessee is dismissed

ITA 183/PAT/2025[2017-18]Status: DisposedITAT Patna20 Aug 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115Section 142(1)Section 144Section 234ASection 250Section 271ASection 272A(1)(d)Section 69A

Hence, keeping in view the newly inserted proviso to section 251(1)(a) of the Act by virtue of which the 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 to the AO for making

Muppalla Padmavathi, Guntur vs. The Income Tax Officer Ward-2(1), Guntur

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

ITA 396/VIZ/2025[2019-20]Status: DisposedITAT Visakhapatnam20 Aug 2025AY 2019-20

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआईटीए. नं. / Ita No. 396/Viz/2025 (A.Y. 2019-20) Muppalla Padmavathi V. Income Tax Officer - Ward – 2(1) D.No. 8-188 Topu Kornepadu Guntur Medical College Road Vatticherukuru Mandal Guntur – 522004 Andhra Pradesh Guntur - 522017 [Pan:Foipm1273L] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented By : Dr. Aparna Villuri, Sr.Ar

Section 147Section 148

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

Pannivizha Service Cooperative Bank Ltd 891, M G Road Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 532/COCH/2025[2020-21]Status: DisposedITAT Cochin20 Aug 2025AY 2020-21

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

relevant extract of which reads as under: “270A. Penalty for under-reporting and misreporting of income. (1) The Assessing Officer or [the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that any person ... amount of income in respect of which the assessee offers an explanation and the Assessing Officer or [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 has disclosed

Pannivizha Service Cooperative Bank Ltd 891, M G Road, Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 531/COCH/2025[2018-19]Status: DisposedITAT Cochin20 Aug 2025AY 2018-19

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

relevant extract of which reads as under: “270A. Penalty for under-reporting and misreporting of income. (1) The Assessing Officer or [the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that any person ... amount of income in respect of which the assessee offers an explanation and the Assessing Officer or [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 has disclosed

Pannivizha Service Cooperative Bank Ltd 891, M G Road Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 530/COCH/2025[2014-15]Status: DisposedITAT Cochin20 Aug 2025AY 2014-15

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

relevant extract of which reads as under: “270A. Penalty for under-reporting and misreporting of income. (1) The Assessing Officer or [the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that any person ... amount of income in respect of which the assessee offers an explanation and the Assessing Officer or [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 has disclosed

Pannivizha Service Cooperative Bank Ltd 891, M G Road, Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 529/COCH/2025[2013-14]Status: DisposedITAT Cochin20 Aug 2025AY 2013-14

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

relevant extract of which reads as under: “270A. Penalty for under-reporting and misreporting of income. (1) The Assessing Officer or [the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that any person ... amount of income in respect of which the assessee offers an explanation and the Assessing Officer or [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 has disclosed

Pannivizha Service Cooperative Bank Ltd 891, M G Road Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 528/COCH/2025[2012-13]Status: DisposedITAT Cochin20 Aug 2025AY 2012-13

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

relevant extract of which reads as under: “270A. Penalty for under-reporting and misreporting of income. (1) The Assessing Officer or [the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that any person ... amount of income in respect of which the assessee offers an explanation and the Assessing Officer or [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 has disclosed

Pannivizha Service Cooperative Bank Ltd 891, Mg Road Pannivizha vs. ITO, Ward 2, Kollam

In the result, ITA No. 531/Coch/2025 (Assessment Year 2018-2019) and ITA No

ITA 527/COCH/2025[2011-12]Status: DisposedITAT Cochin20 Aug 2025AY 2011-12

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri K. Krishna Kumar, CAFor Respondent: Ms. Neethu S, Sr. DR
Section 250Section 270ASection 271(1)(c)Section 80PSection 80P(2)(a)Section 80P(2)(d)

relevant extract of which reads as under: “270A. Penalty for under-reporting and misreporting of income. (1) The Assessing Officer or [the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that any person ... amount of income in respect of which the assessee offers an explanation and the Assessing Officer or [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 has disclosed

R V R Nagesh Legal Heir of Late Vengattarayalu Rajan, Kanchipuram vs. Income Tax Officer, Non Corp Ward - 22(4), Tambaram

ITA 789/CHNY/2025[2011-12]Status: DisposedITAT Chennai20 Aug 2025AY 2011-12

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.789/Chny/2025

Section 271(1)Section 271(1)(c)Section 274

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAI श्री एबी टी. वर्की, न्यायिक

Rinoo, Pimpri- Chinchwad vs. Income Tax Officer, Thane

In the result, grounds of appeal of assessee are allowed for statistical purpose

ITA 918/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Aug 2025AY 2017-18

Bench: Shri Pawan Singh& Shri Omkareshwar Chidara(Physical Hearing)

Section 115BSection 144Section 147Section 254(1)Section 69A

facts and circumstances of the case and as per the law, the National Faceless Appeal Centre/Commissioner of Income Tax (Appeals) ["the learned Commissioner (Appeals)] erred in dismissing the appeal on the limitation and without adjudicating on merits. Thus, the delay of 759 days in filing the appeal before the learned ... Commissioner (Appeals) may be condoned and the matter may be remanded back/restored back to the file of the learned Commissioner (Appeals) for adjudication on merits. 2. In the facts and circumstances of the case and as per the law, the addition of Rs. 43,93,000/- as made

Naval Kishor Mundra, Mumbai vs. Income Tax Officer-4(2)(1), Mumbai

In the result, the appeal is accordingly allowed for

ITA 4200/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Aug 2025AY 2015-16

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhan

Section 143(1)Section 143(3)Section 148Section 250Section 69

sake of clarity, section 251(1) is culled out 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 such appeal ... Proviso" to Section 251(1) of the Act, reads as under: "4. Considering the huge pendency of appeals and disputed tax demands at the Commissioner (Appeals) stage, it is proposed that the cases where assessment order was passed as best judgement case under section 144 of the Act, Commissioner (Appeals

Samta Mittal, Faridabad vs. Income Tax Officer, Delhi

In the result, the appeal of the assessee is dismissed

ITA 1391/DEL/2025[2018-19]Status: DisposedITAT Delhi20 Aug 2025AY 2018-19

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2018-19 Samta Mittal Vs. Ito 601, Royal Retreat, New Delhi Surajkund, Faridabad Pan No. Agzpm5730G (Appellant) (Respondent)

Section 115BSection 144Section 234ASection 251(1)(a)Section 69A

true and correct estimation of income of the appellant. (iii) 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— in an appeal against an order of assessment, he may confirm, reduce, enhance or annul the assessment; 1. [Provided that where

Uvej Mohammad, Bhopal vs. CIT Appeals Faceless, New Delhi

Appeal is allowed for statistical purpose

ITA 112/IND/2025[2018-19]Status: DisposedITAT Indore19 Aug 2025AY 2018-19

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

Section 142(1)Section 144Section 147

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.”. He further

Peeyush Agarwal, Jaipur, Rajasthan vs. ITO, Ward 1(5), Jaipur, Rajasthan

In the result Ground and 1 and 2 raised by the assessee are allowed

ITA 488/JPR/2025[2017-18]Status: DisposedITAT Jaipur19 Aug 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI GAGAN GOYAL (Accountant Member)

For Appellant: Shri Vijay Goyal, C.A. &For Respondent: Mrs. Alka Gautam, CIT
Section 115BSection 143(2)Section 143(3)Section 145(3)Section 250Section 68Section 69A

enhancement of assessment/tax liability. The provisions of section 251(2) as stood for the assessment years under consideration is as under:­ “2) The Commissioner (Appeals)] shall not enhance an assessment or a penalty or reduce the amount of refund unless the appellant has had a reasonable opportunity of showing cause

Akshat Education and Charitable Trust, Anand vs. The ITO, Ward- Exemption, Vadodara

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

ITA 457/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad19 Aug 2025AY 2020-21

Bench: Ms Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.457/Ahd/2025 िनधा"रण वष" /Assessment Year : 2020-2021 Akshat Education & Charitable The Income Tax Officer, Trust, बनाम Ward (Exemption), / 5/35, Gosainu Faliyu, Vadodara. V/S. Asodar Borsad Road, Asodar, Anand-388307. (Gujarat) "थायी लेखा सं./Pan: Aaeta2211K अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Mehul Thakkar, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 14/08/2025 घोषणा की तारीख /Date Of Pronouncement: 19/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] This Appeal By The Assessee Is Directed Against The Order Of The Learned Joint Commissioner Of Income Tax (Appeals)-2, Coimbatore [Hereinafter Referred To As “Ld. Cit(A)”] Dated 25.01.2025, Passed Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”] For The Assessment Year 2020–21. The Impugned Order Arises Out Of The Akshat Education & Charitable Trust Vs. Ito(E) Assessment Year 2020-21

For Appellant: Shri Mehul Thakkar, ARFor Respondent: Shri Rignesh Das, CIT-DR
Section 11Section 12ASection 12A(1)(b)Section 139(1)Section 143(1)Section 250

Aggrieved by the order of CIT(A), the assessee is in appeal before us raising following grounds of appeal: 1. That the Ld. Joint Commissioner (Appeals)-2, Combatore, erred in law and on facts in dismissing the appeal for non-prosecution without adjudicating on the merits of the case, thereby ... denying the appellant's right to be heard. 2. That the Ld. Joint Commissioner (Appeals) failed to appreciate that the CPC had erred in assessing the income at gross receipts of Rs. 1,99,48,893/-, without allowing legitimate revenue expenses, contrary to the settled principle that only net income

Narpatsinh Prabhatsinh Solanki, Surat vs. ITO, Ward-1, Surat

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

ITA 129/SRT/2025[2011-12]Status: DisposedITAT Surat18 Aug 2025AY 2011-12

Bench: Shri Dinesh Mohan Sinha, J

Section 143(2)Section 144Section 148Section 250Section 253(1)Section 254(1)Section 69A

have filed an appeal under section 253(1) of the Income Tax Act, 1961 on 03.02.2025 vide ITA No.129/SRT/2025 against the order of the Commissioner (Appeals) relating to AY 2011-12 made on 08.08.2024, which was uploaded on the Income Tax e-filing portal under e- proceedings. Though this appeal

Agry Business Centre, Bhavnagar vs. The ITO, Ward-1(9), Bhavnagar

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

ITA 944/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad14 Aug 2025AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalagry Business Centre, Income Tax Officer, Vs. Limbada Hanubhana, Ward-1(9), Umarala, Bhavnagar. Bhavnagar-364740. [Pan :Aaofa1500 D] (Appellant) .. (Respondent) Appellant By : Shri Mehul Thakkar, Ar Respondent By: Shri Rajenkumar M Vasavda, Sr. Dr Date Of Hearing 12.08.2025 Date Of Pronouncement 14.08.2025

For Appellant: Shri Mehul Thakkar, ARFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR
Section 147

Faceless Appeal Centre, Delhi, relating to the Assessment Year 2012-13. 2. The assessee has raised the following grounds of appeals: 1. The Ld. Commissioner (Appeals) National Faceless Appeal Centre, Delhi has erred in dismissing the appeal of the appellant and rejecting the request for condonation of delay without considering ... totality of the fact of the case. 2. The Ld. Commissioner (Appeals)_National Faceless Appeal Centre, Delhi has erred in not disposing the following grounds raised before him. Agry Business Centre Vs. ITO Asst. Year : 2012-13 - 2– Ground No. 1 The Ld. A.O. has erred in law in assuming

Income Tax Officer, Kolhapur vs. Dudh Sakhar Us Vahtuk Nagari Sahakari Pat Sanstha Maryadit, Bidri

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

ITA 818/PUN/2025[2018-19]Status: DisposedITAT Pune14 Aug 2025AY 2018-19

Bench: Dr.Manish Borad & Ms.Astha Chandra

For Respondent: Appellant by Shri Amol Khairnar
Section 144Section 147Section 250Section 250(6)Section 251Section 251(1)(a)

brought to section 251 by the Finance Act, 2024 effective from 01.10.2024. Section 251 deals with the powers of the JCIT (Appeals) or the Commissioner (Appeals) and proviso to sub-section (1) of section 251 reads as under : “Powers of the [Joint Commissioner (Appeals) or the] Commissioner (Appeals ... 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: 3 Dudh Sakhar US Vahtuk Nagari Sahakari Patsanstha Maryadit [Provided that where such appeal is against an order of assessment

Pricewaterhouse Coopers Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 1(1), Kolkata

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

ITA 664/KOL/2025[2020-2021]Status: DisposedITAT Kolkata14 Aug 2025AY 2020-2021

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 244ASection 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 order