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“Income-tax Officer”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(25) / Section 1175,006 judgments

The decision most relied on for Income-tax Officer is CIT v. Max India Ltd. (295 ITR 282), cited in 1,162 judgments on BharatTax.

Leading authorities on Income-tax Officer

CIT v. Max India Ltd.
295 ITR 282 · 2007 · Supreme Court
1,162
citing judgments

Under Section 263, an assessment order is not erroneous and prejudicial to the interest of the revenue merely because the Principal Commissioner disagrees with the Assessing Officer's (AO) view, particularly if the AO has adopted one of two permissible views in law, unless that view is completely unsustainable. If due inquiries were made, the AO's order does not become erroneous solely because the fact of inquiries was not recorded.

Dhakeshwari Cotton Mills Ltd. v. CIT
26 ITR 775 · 1954 · Supreme Court
1,061
citing judgments

Corroborative evidence is essential to support evidence found on third-party premises, and an assessment cannot be based on suspicion, surmises, or conjecture.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Union of India v. Ashish Agarwal
444 ITR 1 · 2022 · Supreme Court
524
citing judgments

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

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.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

An assessment can be reopened if there is tangible material indicating escapement of income, demonstrating a live link between the material and the reasons recorded for reopening. The Assessing Officer must apply their mind to the material facts, and the sanction under section 151 should not be based on borrowed satisfaction.

Paul Mathews & Sons. v. CIT
263 ITR 101 · 2003 · High Court
266
citing judgments

A statement recorded under Section 133A of the Income-tax Act has no evidentiary value because Section 133A does not empower an Income-tax Officer to examine any person on oath.

Navnitlal C. Javeri v. K.K. Sen
56 ITR 198 · 1965 · Supreme Court
230
citing judgments

The Supreme Court holds that circulars issued by the Central Board of Direct Taxes (CBDT) are binding on all officers and persons employed in the execution of the Income-tax Act. These circulars are binding even if they deviate from the provisions of the Act, particularly when issued to relieve hardships.

Judgments citing Income-tax Officer

Ajab Singh, Morena vs. Income Tax Officer 1 Morena, Morena

In the result, the appeal is allowed for statistical purposes

ITA 479/AGR/2025[2018-19]Status: DisposedITAT Agra17 Dec 2025AY 2018-19

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2018-19

Section 139Section 144Section 148Section 250Section 69ASection 69C

BEFORE : SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER Assessment Year: 2018-19 Ajab Singh, Singhroli, Jovra, Vs. Income-tax Officer-1, Morena (MP). Morena PAN :HKDPS3512R (Appellant) (Respondent) Assessee by Sh. Rajendra Sharma, Advocate Department by Sh. Shailendra Srivastava, Sr. DR Date of hearing

Krishna Kumar Gupta, Etah vs. National Faceless Assessment Center, Delhi

In the result, the appeal is allowed for statistical purposes

ITA 401/AGR/2025[2014-15]Status: DisposedITAT Agra17 Dec 2025AY 2014-15

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2014-15

Section 143(2)Section 144BSection 147Section 148Section 158BSection 250Section 250(6)Section 68

BEFORE : SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER Assessment Year: 2014-15 Krishna Kumar Gupta, 157, Vs. Income-tax Officer, Kailash Ganj, Etah (UP). Ward 4(3)(1), Etah. PAN :AGZPG4047N (Appellant) (Respondent) Assessee by None Department by Sh. Shailendra Srivastava, Sr. DR Date

Smt.Mithlesh Gupta, Morena vs. ITO, Ward 1, Morena

In the result, the appeal is dismissed as withdrawn

ITA 241/AGR/2025[2017-18]Status: DisposedITAT Agra17 Dec 2025AY 2017-18

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 250

AGRA BEFORE : SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUNIL KUMAR SINGH, JUDICIAL MEMBER ITA No. 241/Agr/2025 Assessment Year: 2017-18 Vs. Income-tax Officer, Smt. Mithlesh Gupta, Ward No. 06, Sabji Mandi Road, Morena. Ward-1, Morena PAN:AULPG6201E (Appellant) (Respondent) Assessee by Department by Sh. Amit Singhal

Karjala Seva Sahkari Mandli Limited, Amreli vs. The ITO Ward-3(1)(4), Rajkot-Amreli, Rajkot

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

ITA 423/RJT/2025[2018-19]Status: HeardITAT Rajkot17 Dec 2025AY 2018-19

Bench: Dr. Arjun Lal Saini

For Respondent: Shri Abhimanyu Singh Yadav, Sr. DR
Section 147Section 250

MEMBER arent arte PITA No. 423/RJT/2025 (Assessment Year: 2018-19) (Hybrid Hearing) Karjala Seva Sahkari Mandli | Vs. Ltd., Karjala, Savarkundla, Amreli-364 515 Income-tax Officer, Ward- 3(1)(4), Rajkot-Amreli, Aayakar Bhavan, Race Course Ring Road, Rajkot-360 001 SAAS. /STS3ITA./PAN/GIR No.: AAKFK 8798 F (3rfrereff/A ppellant

Ashok Hirachand Shah, Panvel vs. Assessing Officer Ward 2, Panvel

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

ITA 812/PUN/2025[2011-12]Status: DisposedITAT Pune17 Dec 2025AY 2011-12

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.812/Pun/2025 धििाारण वर्ा / Assessment Year : 2011-12 Ashok Hirachand Shah, Assessing Officer, Plot No. 4, Mangal Bunglow, Ward – 2, Panvel Road No. 5, Sector No. 19, Vs. New Panvel, Tal.-Panvel-410206 Pan : Acdps4800M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Ajinkya Shah Department By : Shri Rajesh Gawali Date Of Hearing : 09-12-2025 Date Of 17-12-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 20.01.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. Denial Of Natural Justice & Proper Opportunity The Learned Commissioner Of Income Tax (Appeals) Erred In Dismissing The Appeal Without Considering That The Appellant Was Denied Proper Opportunity & Natural Justice During The Assessment Proceedings. The Assessing Officer Called For Information At The Far End Of The Assessment Proceedings On 19/11/2018 & Despite The Appellant'S Authorized Representative Submitting The Details On 19/12/2018, The Ao Failed To Discuss Or Consider The Same. The Matter Ought To Have Been Remanded Back For Fresh Adjudication To Allow Proper Analysis Of The Transactions. 2. Addition Without Specifying The Section The Cit(A) Erred In Upholding The Addition Of Rs. 1,49,05,289/- Made By The Ao Without Specifying The Section Under Which The Addition Was Made. The Non-Mention Of The Specific Section Renders The Assessment Order Bad In Law, As It Violates The Principles Of Natural Justice & Transparency In Taxation. 3. Failure To Discharge Onus Under Section 69A

For Appellant: Shri Ajinkya ShahFor Respondent: Shri Rajesh Gawali
Section 147Section 69A

Arif Vs ACIT ITA No. 976/Bang./2022 (d) Namdev Arora Vs CIT Jalandhar (2016) 72 taxmann.com 124 (P&H) (e) Rajmeet Singh v. Income-tax Officer [2024] 160 taxmann.com 83 (Jharkhand) (f) Dr. Prakash Tiwari Vs Commissioner of Income-tax [1983] 14 Taxman 252 (MP) Thus, the contention

Krishnaveni Kokkula, Hyderabad vs. ITO., Ward-9(1), Hyderabad

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

ITA 558/HYD/2025[2016-17]Status: DisposedITAT Hyderabad17 Dec 2025AY 2016-17

Bench: Us:

Section 147Section 69A

would further observe that the Hon’ble High Court of Jurisdiction in its order in the case of Yashnu Yasasvi Polucherla Vs. Income-tax Officer (2025) 179 taxmann.com 470 (Telangana), had held that as its earlier order in the case of Kankanala Ravindra Reddy Vs. ITO & 2 Others (supra

Raja Satheeshkumar, Salem vs. ITO, Ward-1(6), Salem

The appeal of the assessee is partly allowed for statistical purposes

ITA 2942/CHNY/2025[2011-12]Status: DisposedITAT Chennai17 Dec 2025AY 2011-12

Bench: Hon’Ble Shri George George K & Before Hon’Ble Shri Inturi Rama Raoआयकर अपील सं./Ita No.2942/Chny/2025 Assessment Years: 2011-12 Raja Satheeshkumar, Income Tax Officer, H.No.2/167, Cecg Nagar, Alagapuram, Ward-1(6), Periyapudur, Salem, Salem. Tamil Nadu-636 016. [Pan: Auqps9210G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.Bhupendran S, Advocate प्रत्यर्थी की ओर से /Revenue By : Ms.R.Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 16.12.2025 घोषणा की तारीख /Date Of Pronouncement : 17.12.2025 आदेश / O R D E R Per Inturi Rama Rao, A.M :

For Appellant: Mr.Bhupendran S, AdvocateFor Respondent: Ms.R.Anitha, Addl.CIT
Section 139(1)Section 142(1)Section 143Section 143(3)Section 148Section 246Section 246A

assessment pursuant to the directions of the Tribunal under section 33(4) (section 254 of the 1961 Act). It was observed: "...The Income-tax Officer's duty to assess the total income of the assessee and to determine the sum payable by him on the basis of the return under ... something again with regard to the assessment he has already made and that by way of revision or amendment, the Income-tax Officer must be held to be still under section 23 of the Act on the process of assessing the total income of the assessee and determining

M/S. Devisha Infrastructure Pvt Ltd, Mumbai vs. ITO Ward 6(2)(2), Mumbai

In the result, appeal of the assessee ITA No

ITA 5782/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Dec 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Nishit GandhiFor Respondent: Shri Umashankar Prasad (SR DR)
Section 143(3)Section 147Section 148Section 148ASection 151Section 250Section 282ASection 41(1)

Assessment Years 2017-18 & 2019-20, date of order 21/08/2025. The impugned orders emanated from the order of the Learned Income-tax Officer, Ward-6(2)(2), Mumbai(in short, ‘Ld.AO’) for A.Y. 2017-18, under section 143(3) of the Act, date of order 30/12/2019 and order passed ... decision of Hon'ble Bombay High Court in case of Madhuri Sameer Gokhale vs. Addl. Joint/ Deputy Asst. Commissioner of Income-tax/ Income-tax Officer, National Faceless Assessment Centre [2025] 172 taxmann.com 696 (Bombay) and also on the decision of Cheftalk Food and Hospitality Services (P) Ltd v. Income Tax

M/S. Devisha Infrastructure Pvt Ltd, Mumbai vs. ITO Ward 6(2)(2), Mumbai

In the result, appeal of the assessee ITA No

ITA 5781/MUM/2025[2019-20]Status: DisposedITAT Mumbai17 Dec 2025AY 2019-20

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Nishit GandhiFor Respondent: Shri Umashankar Prasad (SR DR)
Section 143(3)Section 147Section 148Section 148ASection 151Section 250Section 282ASection 41(1)

Assessment Years 2017-18 & 2019-20, date of order 21/08/2025. The impugned orders emanated from the order of the Learned Income-tax Officer, Ward-6(2)(2), Mumbai(in short, ‘Ld.AO’) for A.Y. 2017-18, under section 143(3) of the Act, date of order 30/12/2019 and order passed ... decision of Hon'ble Bombay High Court in case of Madhuri Sameer Gokhale vs. Addl. Joint/ Deputy Asst. Commissioner of Income-tax/ Income-tax Officer, National Faceless Assessment Centre [2025] 172 taxmann.com 696 (Bombay) and also on the decision of Cheftalk Food and Hospitality Services (P) Ltd v. Income Tax

The Institute of Marine Engineers India, Mumbai vs. ITO Ward 2(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5666/MUM/2025[2009-10]Status: DisposedITAT Mumbai17 Dec 2025AY 2009-10

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Karthik Natarajan, CAFor Respondent: Shri Virabhadra Mahajan, SR DR
Section 11Section 143(3)Section 250Section 254

SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI ANIKESH BANERJEE, JUDICIAL MEMBER I.T.A No.5666/Mum/2025 (Assessment Year: 2009-10) The Institute of Marine vs Income-tax Officer, Ward 2(4), Engineers India, Mumbai, Room NO.699, 6th Floor IMEI House, Sector 19, Plot 94, Nerul, Navi Mumbai – 400 706 MTNL Bldgh, Cumballa ... Assessment Year 2009-10, date of order 17/07/2025. The impugned order was emanated from the order of the Learned Income-tax Officer (E)-2(4), Mumbai (in short, ‘Ld.AO’) passed under section 143(3) read with section 254 of the Act, date of order 29/09/2017. 2. The assessee has taken

Eli Lilly and Company (India) Private Ltd., Haryana vs. ACIT Circle-1(1), Haryana

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

ITA 973/DEL/2022[2018-19]Status: DisposedITAT Delhi17 Dec 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Amitabh Shukla[Assessment Year:2018-19] Eli Lilly & Company Assistant Commissioner Of Income (India) Private Limited (‘Eli Tax, Circle-1(1), Haryana, Lilly India”) Vs Additional/Joint/Deputy/Income Plot No.92, Sector-32, Tax Officer/National Faceless Institutional Area, Jharsa, Appeal Centre, Gurgaon, Haryana-122001 New Delhi Pan Aaace8901F Appellant Respondent Assessee By Shri K. M. Gupta, Adv. & Shri Jaskaran Singh, Ar Revenue By Shri Dharm Veer Singh, Cit(Dr) Date Of Hearing 15.12.2025 Date Of Pronouncement 17.12.2025

Section 143(3)Section 144Section 144BSection 270ASection 92C(3)Section 92D

section 144B of the Income-tax Act, 1961 (the Act) ('assessment order) passed by the Additional/ Joint/ Deputy/ Assistant Commissioner of Income-tax/ Income-tax Officer, National Faceless Assessment Centre, Delhi (Ld. AO') pursuant to the directions passed by the Hon'ble Dispute Resolution Panel

Shri Narayan Jan Kalyan Ewam Gramin Vikas Samiti, Barnahal Mainpuri vs. ITO Exemption Ghaziabad, Ghaziabad

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

ITA 435/AGR/2025[2017-2018]Status: DisposedITAT Agra16 Dec 2025AY 2017-2018

Bench: : Shri S. Rifaur Rahmanassessment Year: 2017-18

Section 143(3)

APPELLATE TRIBUNAL, AGRA (SMC) BENCH, AGRA BEFORE : SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER Assessment Year: 2017-18 Shri Narayan Jan Kalyan Ewam Vs. Income-tax Officer(Exemption), Gramin Vikas Samiti, Barnahal, Ghaziabad. Mainpuri (UP). PAN :AAOAS9172N (Appellant) (Respondent) Assessee by None Department by Shri Shailendra Srivastava, Sr. DR Date

Rakeshkumar Mahendrakumar Shah, Ahmedabad vs. The ACIT, Central Circle-1(3), Ahmedabad

The appeal of the assessee stand dismissed, and the order of the CIT(Appeals) is hereby affirmed in toto

ITA 1724/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Ms. Urvashi Sodhan, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 132Section 132(4)Section 139(1)Section 143(1)Section 143(3)Section 28Section 69A

Dulari Digital Photo Services (P.) Ltd. [2012] 24 taxmann.com 31 (Chd.), and reiterated by the Bangalore Bench of the Tribunal in Income-tax Officer v. Ramachandra Setty & Sons [2024] 163 taxmann.com 666 (Bang.-Trib.), where it has been held that a sworn statement must be corroborated by independent material

ACIT Central Circle 1(3), Ahmedabad vs. Rakeshkumar Mahendrakumar Shah, Ahmedabad

The appeal of the assessee stand dismissed, and the order of the CIT(Appeals) is hereby affirmed in toto

ITA 1713/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2022-23

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Ms. Urvashi Sodhan, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 132Section 132(4)Section 139(1)Section 143(1)Section 143(3)Section 28Section 69A

Dulari Digital Photo Services (P.) Ltd. [2012] 24 taxmann.com 31 (Chd.), and reiterated by the Bangalore Bench of the Tribunal in Income-tax Officer v. Ramachandra Setty & Sons [2024] 163 taxmann.com 666 (Bang.-Trib.), where it has been held that a sworn statement must be corroborated by independent material

Rupal Chemicals, Ratnagiri vs. ITO Ward 1, Ratnagiri

In the result Appeal of the assessee is allowed for statistical purposes

ITA 2588/PUN/2025[2021-22]Status: DisposedITAT Pune16 Dec 2025AY 2021-22

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपीऱ सं./Ita No.2588/Pun/2025 नििाारण वर्ा / Assessment Year: 2021-2022 Vs Ito, Ward 1, Rupal Chemicals, D/13, Midc, Lote Ratnagiri Parashuram, Taluka Khed, District Ratnagiri-415722 Maharashtra Pan-Aabfr7940R Appellant Respondent

For Appellant: Shri Ramkrishna LingsurFor Respondent: Shri Ganesh B Budruk-
Section 133(6)Section 143Section 143(2)Section 144B

existence of an agreement between the employer and the employee and the fact of actual payment, no discretion is left to the Income-tax Officer except to hold that the payment was made wholly and exclusively for the purposes of the business. Although the payment might have been made

Dy. Commissioner of Income Tax, Satara Circle, Satara vs. Kay Bouvet Engineering Limited, Satara

In the result, both the appeals filed by the Revenue and both the COs filed by the assessee are dismissed

ITA 1392/PUN/2025[2019-20]Status: DisposedITAT Pune16 Dec 2025AY 2019-20

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

For Appellant: Shri Ashwani Kumar &For Respondent: S/Shri Amol Khairnar CIT-DR and Manish M. Mehta
Section 131Section 133ASection 143(1)(a)Section 143(3)Section 148

confer such power to examine a person on oath, the same has been expressly provided whereas section 133A does not empower any Income-tax Officer to examine any person on oath. Thus, in contradistinction to the power under section 133A, section 132(4) of the Income-tax Act enables ... argument of learned counsel for the appellant that the statement elicited during the survey operation has no evidentiary value and the Income-tax Officer was well aware of this." 14. Moreover, the word „may‟ used in Section 133A(3)(iii) of the Act clarifies beyond doubt that the material collected

Dy Commissioner of Income Tax, Satara vs. Kay Bouvet Engineering Limited, Satara

ITA 1374/PUN/2025[2018-19]Status: DisposedITAT Pune16 Dec 2025AY 2018-19

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

For Respondent: Shri Ashwani Kumar &
Section 131Section 133ASection 143(1)(a)Section 143(3)Section 148

confer such power to examine a person on oath, the same has been expressly provided whereas section 133A does not empower any Income-tax Officer to examine any person on oath. Thus, in contradistinction to the power under section 133A, section 132(4) of the Income-tax Act enables ... argument of learned counsel for the appellant that the statement elicited during the survey operation has no evidentiary value and the Income-tax Officer was well aware of this." 14. Moreover, the word

Sumangal Jewels P. Ltd., Kolkata vs. D.C.I.T., CC-4(3), Kolkata

Appeal of the assessee is allowed

ITA 2357/KOL/2024[2009-2010]Status: DisposedITAT Kolkata16 Dec 2025AY 2009-2010
Section 132Section 133ASection 139(1)Section 147Section 148Section 250Section 68

from outside source as has been held by the Hon'ble Delhi High Court in case of Sarthak Securities Co. (P.) Ltd. vs. Income-tax Officer- Ward 7(3) [2010] 329 ITR 110 (Delhi, wherein it is held as under:- “3. Further, the alleged information provided by the Addl

Bhadravathi Ramalingasetty Manjunath Setty, Bhadravathi vs. ITO Ward-1 Tps, Shimoga

In the result, appeal filed by the assessee is allowed

ITA 1459/BANG/2025[2018-19]Status: DisposedITAT Bangalore16 Dec 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2018-19

For Appellant: Sri Sachin S Rao, A.RFor Respondent: Sri Balusamy N., D.R
Section 139Section 139(4)Section 139(9)Section 143(2)Section 143(3)Section 250Section 271BSection 44A

Bhadravathi Ramalingasetty Manjunath Setty, Shivamogga Page 9 of 12 (w.e.f. 1.7.1995).], the [Assessing Officer] [ Substituted by Act 4 of 1988, Section 2, for " Income-tax Officer" (w.e.f. 1.4.1988).] may direct that such person shall pay, by way of penalty, a sum equal to one-half per cent. of the total

Ankita Badal Mittal, Mumbai vs. Ward 3(3)(1), Mumbai

In the result, the appeal filed by the assessee stands partly allowed

ITA 5484/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Dec 2025AY 2017-18

Bench: Shri Sandeep Gosain

Section 147Section 148Section 149Section 151Section 250Section 68Section 69A

hereinabove. Hence, the present submissions are also restricted to the same. 6 Ankita Badal Mittal, Mumbai. a. In Dhanraj Govindram Kella v. Income-tax Officer, being Order dated 08.07.2025 in Special Civil Application No.6387 of 2023 while dealing with assessment year 2017-18 (see the facts at pages