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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)

DCIT Central Circle-1(1), Ahmedabad vs. Crystal Ceramic Industries Limited, Ahmedabad

In the result, the appeals filed by the Revenue in ITA Nos

ITA 860/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)Section 147Section 148Section 68

made addition of Rs. 1.45 crore under section 68 on ground that loan taken from one ‘IA’ was not explained satisfactorily - On appeal, Commissioner (Appeals) was satisfied with respect to genuineness of transaction and creditworthiness of MA' and, therefore, deleted addition - It was found that total loan

DCIT Central Circle 1(1) Ahmedabad, Ahmedabad vs. Crystal Ceramic Industries Limited, Ahmedabad

In the result, the appeals filed by the Revenue in ITA Nos

ITA 859/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2015-16

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)Section 147Section 148Section 68

made addition of Rs. 1.45 crore under section 68 on ground that loan taken from one ‘IA’ was not explained satisfactorily - On appeal, Commissioner (Appeals) was satisfied with respect to genuineness of transaction and creditworthiness of MA' and, therefore, deleted addition - It was found that total loan

Crystal Ceramics Industries Limited, Ahmedabad vs. The DCIT, Central Circle-1(1), Ahmedabad

In the result, the appeals filed by the Revenue in ITA Nos

ITA 682/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2013-14

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 143(3)Section 147Section 148Section 68

made addition of Rs. 1.45 crore under section 68 on ground that loan taken from one ‘IA’ was not explained satisfactorily - On appeal, Commissioner (Appeals) was satisfied with respect to genuineness of transaction and creditworthiness of MA' and, therefore, deleted addition - It was found that total loan

Dinesh Jawaraji Parihar, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 4(2), Mumbai

In the result, the appeal filed by the assessee is hereby allowed

ITA 5634/MUM/2025[2019-20]Status: DisposedITAT Mumbai24 Feb 2026AY 2019-20

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Umashankar Prasad, CIT-DR
Section 132Section 143(2)Section 153CSection 250Section 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

Dinesh Jawaraji Parihar, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 4(2), Mumbai

In the result, the appeal filed by the assessee is hereby allowed

ITA 5633/MUM/2025[2018-19]Status: DisposedITAT Mumbai24 Feb 2026AY 2018-19

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri Umashankar Prasad, CIT-DR
Section 132Section 143(2)Section 153CSection 250Section 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

Dinesh Jawaraji Parihar, Mumbai vs. Assistant Commissioner of Income Tax Central Circle -4(2), Mumbai

ITA 5629/MUM/2025[2017-18]Status: DisposedITAT Mumbai24 Feb 2026AY 2017-18

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Ms. Rutuja Pawar, ARFor Respondent: Shri Umashankar Prasad, CIT-DR
Section 132Section 143(2)Section 153CSection 250Section 69

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, AM AND MS. KAVITHA RAJAGOPAL, JM

Rohtash Singla Jimmi, Punjab vs. ITO, Ward 1, Barnala

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

ITA 594/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh23 Feb 2026AY 2015-16

Bench: The Tribunal. The Assessee Has Filed An Application For Condonation Of Delay Supported By An Affidavit Explaining The Reasons For Late Filing. In The Affidavit, The Assessee Has Stated That He Is A Physically Handicapped Person Suffering From Hearing & Speech Disability Since Birth & Is Entirely Dependent Upon Others For Handling His Income Tax Matters. It Has Further Been Explained That His Earlier Accountant, Who Was Looking After The Tax Affairs, Left The Job & Did Not Inform The Assessee Regarding The Appellate Proceedings And, Because Of His Disability, The Assessee Could Not Monitor The Proceedings & Came To Know About The Appellate Order Only Later When He Consulted Another Person After Receipt Of Subsequent Penalty Related Communication. It Has Also Been Submitted That The Delay Was Neither Intentional Nor Deliberate But Occurred

For Appellant: Shri Nagesh Behl, Advocate (Virtual)For Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 147Section 148

appeal is admitted for adjudication on merits. 4. In the present appeal Assessee has raised the following grounds: 1. That order of the Commissioner (Appeals) is contrary to the law and the facts of the case, Commissioner (Appeals) erred in passing ex-parte order without giving opportunity of being heard ... assessee. 2. That without prejudice to above grounds, order of the Commissioner (Appeals) is contrary to the law and the facts of the case, in so far it is passed without passing order on merits of the case. 3. Looking into the facts and circumstances of the case

Naushad Ali Abdul Haq Shaik, Mumbai vs. Income Tax Officer 42(2)(4), Mumbai

ITA 7339/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Akshay JainFor Respondent: Mr. Swapnil Choudhari, Sr. DR
Section 245

assessment or o the assessment or penalty: Further, section 249(3) reads as under Further, section 249(3) reads as under: The Commissioner (Appeals) may admit an appeal after the The Commissioner (Appeals) may admit an appeal after the The Commissioner (Appeals) may admit an appeal after the expiration ... present such appeal before the 1st day of July, presen 2000. 1st day of July, presen 2000. 1. The Commissioner (A 1. The Commissioner (Appeals) may ) may admit an appeal after the ppeals) may ) may admit an appeal after the expiration of the said period if he is satisfied that

Naushad Ali Abdul Haq Shaikh, Mumbai vs. Income Tax Officer 42(2)(4), Mumbai

ITA 7338/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Feb 2026AY 2015-16

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Akshay JainFor Respondent: Mr. Swapnil Choudhari, Sr. DR
Section 245

assessment or o the assessment or penalty: Further, section 249(3) reads as under Further, section 249(3) reads as under: The Commissioner (Appeals) may admit an appeal after the The Commissioner (Appeals) may admit an appeal after the The Commissioner (Appeals) may admit an appeal after the expiration ... present such appeal before the 1st day of July, presen 2000. 1st day of July, presen 2000. 1. The Commissioner (A 1. The Commissioner (Appeals) may ) may admit an appeal after the ppeals) may ) may admit an appeal after the expiration of the said period if he is satisfied that

Sejal Paresh Chopra, Mumbai Maharahstra vs. Central Circle 4(2) ACIT Assistant Commissioner of Income Tax, Mumbai Maharashtra

In the result, the appeal filed by the assessee is hereby allowed

ITA 7062/MUM/2025[2020-21]Status: DisposedITAT Mumbai23 Feb 2026AY 2020-21

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Vimal Punmiya, ARFor Respondent: Shri Vivek Perampurna, CIT-DR
Section 132Section 142(1)Section 250Section 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

Sejal Paresh Chopra, Mumbai Maharashtra vs. Central Circle 4(2) ACIT Assistant Commissioner of Income Tax, Mumbai Maharashtra

In the result, the appeal filed by the assessee is hereby allowed

ITA 7061/MUM/2025[2019-20]Status: DisposedITAT Mumbai23 Feb 2026AY 2019-20

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Appellant: Shri Vimal Punmiya, ARFor Respondent: Shri Vivek Perampurna, CIT-DR
Section 132Section 142(1)Section 250Section 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

Dinabandhu Foundation for Educational Research & Socio Economic Development, Bhubaneswar vs. Additional/Joint/Deputy/Assistant Commissioner/Income Tax Officer, NFAC, Delhi

In the result, appeal of the assessee is allowed and stay application of the assessee stands dismissed

ITA 450/CTK/2025[2018-19]Status: HeardITAT Cuttack20 Feb 2026AY 2018-19

Bench: Shri George Mathan & Shri Madhusudan Sawdiaआयकर अपील सं/Ita No.450/Ctk/2025 रोक आवेदन सं/Sa No.6/Ctk/2025 (Arising Out Of Ita No.450/Ctk/2025) (नििाारण वर्ा / Assessment Year : 2018-2019) Vs Additional/Joint/Deputy/Assistant Dinabandhu Foundation For Educational Research & Socio Commissioner/Income Tax Economic Development, Officer/Nfac, Delhi A/127, Saheed Nagar, Bhubaneswar-751007 Pan No. :Aaatd 7338 L (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Shri Dilip Kumar Mohanty, Advocate & Shri Pradyumna Kumar Sahu, Advocate राजस्व की ओर से /Revenue By : Shri Ashim Kumar Chakraborty, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 20/02/2026 घोषणा की तारीख/Date Of Pronouncement : 20/02/2026 आदेश / O R D E R Per Bench : The Assessee Has Filed Stay Application Along With Appeal In Ita No.450/Ctk/2025 For The Assessment Year 2018-2019 Against The Order Dated 21.07.2025 Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Thereby Disallowing The Exemption Claimed By The Assessee Trust U/S.11(2) Of The Act On The Ground That The Purpose Mentioned In Form No.10 Was Too Vague & Lacked The Required Specificity. 2. It Was Submitted By The Ld.Ar That The Assessee Had During The Impugned Assessment Year Filed Its Form No.10 Which Reads As Follows:-

For Appellant: Shri Dilip Kumar Mohanty, AdvocateFor Respondent: Shri Ashim Kumar Chakraborty, CIT-DR
Section 11Section 11(2)

requirement of the trust's projects. The Assessing Officer having rejected assessee's explanation, disallowed claim of deduction filed under section 11(2). The Commissioner (Appeals) confirmed the view of the Assessing Officer. The Tribunal, however, taking a view that it was not mandatory to specify object in Form

Ameenamma Charitble Trust, Anantapur vs. ITO, (Exemption) Ward-Tirupati, Tirupati

In the result, appeal filed by the assessee Trust is partly allowed in terms of our aforesaid observations

ITA 1841/HYD/2025[2016-17]Status: DisposedITAT Hyderabad20 Feb 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1841/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Ameenamma Charitable Vs. Income Tax Officer Trust, (Exemption) Ward – Anantapur. Tirupati. Pan: Aaeta7403P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ka Sai Prasad, Ca राज" व "ारा/Revenue By: Shri K Vamsi Krishna, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 04/02/2026 घोषणा की तारीख/Date Of 20/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Trust Is Directed Against The Order Passed By The Additional/Joint Commissioner Of Income Tax (Appeals)-1, Chennai, Dated 03/10/2025, Which In Turn Arises From The Order Passed By The Income Tax Officer, Exemption Ward, Tirupati (For Short, “Ao”) Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 14/12/2018 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri KA Sai Prasad, CAFor Respondent: Shri K Vamsi Krishna, Sr.AR
Section 11Section 11(1)Section 11(2)Section 115BSection 12ASection 13(9)Section 139(1)Section 143(2)Section 143(3)Section 250

Income Tax (Appeals) is not correct either on facts or in law, and is therefore liable to be set aside. 2. The Ld. Commissioner (Appeals) erred in dismissing the exemption claim u/s 11 merely for delay in filing Form No. 10, without appreciating that the appellant had already sought ... through a speaking order, and once condonation is granted by the competent authority, the exemption cannot be denied on procedural grounds. 3. The Ld. Commissioner (Appeals) is not justified in upholding the addition of Rs. 11,78,000/- u/s 115BBC as anonymous donations ignoring the complete donor details furnished during

Kavalldeepsingh Nirbhay Singh Thind, Mumbai vs. ITO Ward 3(2), Mumbai

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 8270/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 144Section 147

sake of convenience and judicial coherence. 2. At the very outset, the learned counsel appearing on behalf of the assessee submitted that the learned Commissioner (Appeals) has dismissed the appeals ex parte without adjudicating the issues on merits. It was contended that certain notices were stated to have been issued ... learned counsel, therefore, pleaded that the impugned orders be set aside and the matters be restored to the file of the learned Commissioner (Appeals) for fresh adjudication on merits after affording reasonable and effective opportunity of hearing. It was fairly submitted that the assessee undertakes to fully cooperate

Kavalldeepsingh Nirbhay Singh Thind, Mumbai vs. ITO Ward 3(2), Kalyan

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 8269/MUM/2025[2016-17]Status: DisposedITAT Mumbai20 Feb 2026AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 144Section 147

sake of convenience and judicial coherence. 2. At the very outset, the learned counsel appearing on behalf of the assessee submitted that the learned Commissioner (Appeals) has dismissed the appeals ex parte without adjudicating the issues on merits. It was contended that certain notices were stated to have been issued ... learned counsel, therefore, pleaded that the impugned orders be set aside and the matters be restored to the file of the learned Commissioner (Appeals) for fresh adjudication on merits after affording reasonable and effective opportunity of hearing. It was fairly submitted that the assessee undertakes to fully cooperate

Kavalldeepsingh Nirbhay Singh Thind, Mumbai vs. ITO Ward 3(2), Kalyan

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 8268/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Feb 2026AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 144Section 147

sake of convenience and judicial coherence. 2. At the very outset, the learned counsel appearing on behalf of the assessee submitted that the learned Commissioner (Appeals) has dismissed the appeals ex parte without adjudicating the issues on merits. It was contended that certain notices were stated to have been issued ... learned counsel, therefore, pleaded that the impugned orders be set aside and the matters be restored to the file of the learned Commissioner (Appeals) for fresh adjudication on merits after affording reasonable and effective opportunity of hearing. It was fairly submitted that the assessee undertakes to fully cooperate

ACIT-4(1)(1), Mumbai vs. Quality Application Solutions Pvt. Ltd., Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 7859/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokaracit Circle-4(1)(1) Quality Application Room No. 642, 6Th Solution, Floor, Aayakar Bhavan, Vs. B-Wing, 3Rd Floor, M. K. Road, Mumbai- Interface Building No. 400 020 16, Mindspace Link Road, Malad (W), Mumbai-400 064 Pan/Gir No. Aabca3829K (Applicant) (Respondent) Revenue By Shri Annavaram Kosuri, Ld. Dr Assessee By Shri K. Gopal & Ms. Neha Paranjpe, Ld. Ars Date Of Hearing 18.02.2026 Date Of Pronouncement 20.02.2026

Section 143(3)Section 144BSection 250

otherwise not genuine, an addition cannot be sustained merely on suspicion or on the basis of ratio comparison. 16. The conclusion recorded by the Commissioner (Appeals) reads as under: “2. AO has made addition in this case completely on the basis of surmises and conjectures, by doing mathematical calculation ... trade payables were not genuine, we find no infirmity in the order of the CIT(A).We, therefore, uphold the order of the Commissioner (Appeals) deleting the addition of Rs. 5,60,00,000/-.The ground raised by the Revenue is dismissed. 18. In the result, the appeal

Jitendra Mafatlal Jain, Mumbai vs. ACIT, Central Circle 4(2), Mumbai

ITA 7743/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Hon’Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

Section 115BSection 147Section 153CSection 69

IN THE INCOME TAX APPELLATE TRIBUNAL "F" BENCH MUMBAI BEFORE HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER& SHRI BIJAYANANDA PRUSETH

Jitendra Mafatlal Jain, Mumbai vs. ACIT, Central Circle 4(2), Mumbai

ITA 7742/MUM/2025[2019-20]Status: DisposedITAT Mumbai20 Feb 2026AY 2019-20

Bench: Hon'Ble Shri Sandeep Gosain& Shri Bijayananda Pruseth

Section 115BSection 147Section 153CSection 69

IN THE INCOME TAX APPELLATE TRIBUNAL "F" BENCH MUMBAI BEFORE HON'BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER& SHRI BIJAYANANDA PRUSETH

Mahua Cooperative Cold Storage Ltd, Mahua, Vaishali vs. ADIT, CPC, Bengaluru

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

ITA 520/PAT/2024[2021-22]Status: DisposedITAT Patna19 Feb 2026AY 2021-22

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(1)Section 250Section 43BSection 4A

been held in that case that “the view that the Tribunal is confined only to issues arising out of the appeal before the Commissioner (Appeals) takes too narrow a view of the powers of the Tribunal. Undoubtedly, the Tribunal will have the discretion to allow or not allow