“first appeal”

AppealsSection 246ASection 246A5,395 judgments

The decision most relied on for first appeal is CIT v. Union Tyres (240 ITR 556), cited in 135 judgments on BharatTax.

Leading authorities on first appeal

CIT v. Union Tyres

240 ITR 556 · 1999 · High Court

135

citing judgments

The first appellate authority, the Commissioner (Appeals), cannot enhance an assessment by considering a new scope or source of income that was not part of the original assessment proceedings. Its power to enhance under Section 251(1)(a) is restricted to what was originally assessed.

Sanjay Sawhney v. Principal Commissioner of Income-tax

116 Taxmann.com 701 · 2020 · High Court

citing judgments

Rule 27 of the ITAT Rules allows a respondent to defend a favourable order of the CIT(A) by raising grounds decided against them, even without filing an appeal or cross-objection. Such issues can be raised orally and for the first time before the Tribunal.

Sugar Mills Pvt. Ltd. v. CIT

156 ITR 54 · 1985 · High Court

citing judgments

An appellate authority can admit and adjudicate a new legal ground for the first time, even if not raised in earlier appellate proceedings, provided its omission was neither willful nor unreasonable.

Kiran Singh & Ors. v. Chaman Paswan & Ors.

1 SCR 117 · 1955 · Supreme Court

citing judgments

A decree or proceeding initiated by an authority without jurisdiction is a nullity, void ab initio, and its invalidity can be raised at any stage, including in collateral proceedings or for the first time on appeal, as a defect of jurisdiction cannot be cured even by consent.

CIT v. S. Chenniappa Mudaliar

74 ITR 41 · 1969 · Supreme Court

citing judgments

The first appellate authority cannot dismiss an appeal for default without disposing of the grounds on merits. Dismissal without going into the merits is not justified.

Ultratech Cement Ltd. v. Additional Commissioner of Income Tax

408 ITR 500 · 2018 · High Court

citing judgments

A tribunal can exercise its discretion to admit an additional ground of appeal, even if raised for the first time, provided it considers the facts and circumstances of the case.

CIT v. Geo Industries and Insecticides (1) Pvt Ltd.

96 TTJ 211 · 2005 · ITAT

citing judgments

The Income Tax Appellate Tribunal (ITAT) can adjudicate a fresh claim raised for the first time before it, provided it is permissible under the law.

Ramco Cements Ltd. v. DCIT

373 ITR 146 · 2015 · High Court

citing judgments

An assessee can make a claim of deduction for the first time before the appellate authorities.

Judgments citing first appeal

More Mauli Co-Op Credit Society Limited Mumbai, Mumbai vs. Ward 22(2)(1), Mumbai

ITA 5649/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Jan 2026AY 2018-19

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

Section 144Section 234ASection 250Section 80P(2)(a)Section 80P(2)(d)Section 80P(4)

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

Alaknanda Associates, Meerut vs. ITO Ward 1(1)(4), Meerut

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

ITA 5452/DEL/2025[2018-19]Status: DisposedITAT Delhi30 Jan 2026AY 2018-19

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year 2018-19 Ms. Alaknanda Associates, Vs. Income Tax Officer, 00, Shivam Complex, Ward-1(1)(4), Nateshpuram, Kanker-Khera, Meerut Meerut - 250001 Pan No. Aaofm3000C (Appellant) (Respondent)

For Appellant: Shri Raj Kumar Jain, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 143(1)Section 143(1)(a)Section 250Section 36Section 36(1)(va)Section 43B

adjustments were carried out the CPCBangluru and intimation was issued enhancing the assessed income in the captioned assessment years. The CIT(A) in the first appeal has sustained the adjustments towards belated deposits of employees’ contribution to PF/ESIC in the light of the judgment rendered by the Hon’ble Supreme

Rizwan, Mewat vs. Income Tax Officer, Gurgaon

The appeals are allowed for statistical purposes

ITA 2880/DEL/2025[2013-14]Status: DisposedITAT Delhi30 Jan 2026AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Sh. Jitender Wadhwa, CAFor Respondent: Ms. Indu Bala Saini, Sr. DR

Section 144

No.35. 5. The impugned order is however silent as to how and by what mean assessee was given an opportunity of hearing in the first appeal proceedings. 6. The counsel has submitted that the assessee has all the details of creditors/debtors, bills and vouchers. But due to failure of earlier

Rizwan, Mewat vs. Income Tax Officer, Gurgaon

The appeals are allowed for statistical purposes

ITA 2879/DEL/2025[2013-14]Status: DisposedITAT Delhi30 Jan 2026AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Sh. Jitender Wadhwa, CAFor Respondent: Ms. Indu Bala Saini, Sr. DR

Section 144

Pooja Aggarwal, Panchkula vs. ACIT(Central) Shimla, Shimla

In the result, ITA No.1021/Chandi/2025 stand partly allowed

ITA 1027/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh29 Jan 2026AY 2023-24

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL, AM 1. आयकर अपील सं./ ITA No.1021/CHANDI/2025 (निर्धारण वर्ष / Assessment Year: 2023-24) | Sh. Anup Kumar Aggarwal House No.218, Sector-10 Panchkula – 134113 | बनाम / Vs. | ACIT(Central) Shimla 171001 | |---|---|---| | स्थायीलेखासं./जीआइआरसं./PAN/GIR No. | ADJPK-5842-L | | | (अपीलार्थी/Appellant) | : | (प्रत्यर्थी / Respondent) | & 2. आयकर अपीलसं./ ITA No.1027/CHANDI/2025 (निर्धारणवर्ष / Assessment Year: 2023-24) | Ms. Pooja Agga

For Appellant: Sh. Ajay Jain (CA) a/w Shri Lovesh BansalFor Respondent: Smt. Kusum Bansal (CIT) & Shri Rajat Kumar

Section 127Section 139(1)Section 143(2)Section 143(3)Section 28Section 69A

Pooja Aggarwal. 4. Finally, the assessment was framed by Ld. AO at Rs.177.43 Lacs which was subjected to assessee’s further challenge in the first appeal. 5. The assessee assailed the impugned additions by way of elaborate written submissions reiterating the contentions as raised during assessment proceedings. However, the same

Anup Kumar Aggarwal, Panckula vs. ACIT(Central) Shimla, Shimla

In the result, ITA No.1021/Chandi/2025 stand partly allowed

ITA 1021/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh29 Jan 2026AY 2023-24

Bench: SHRI RAJPAL YADAV (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Sh. Ajay Jain (CA) a/w Shri Lovesh BansalFor Respondent: Smt. Kusum Bansal (CIT) & Shri Rajat Kumar

Section 127Section 139(1)Section 143(2)Section 143(3)Section 28Section 69A

Anup Kumar Aggarwal, Panhckula vs. ACIT(Central) Shimla, Shimla

Appeal stand allowed

ITA 1020/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh29 Jan 2026AY 2022-23

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1020/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2022-23) Sh. Anup Kumar Aggarwal Acit (Central) बनाम/ Vs. House No.218,Sector-10 Shimla 171001 Panchkula – 134113 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adjpk-5842-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) A/W Shri Lovesh Bansal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 29-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2022-23 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 31-07-2025 In The Matter Of An Assessment Framed By Ld. Ao U/S 143(3) Of The Act On 27-09-2024. The Assessee Is Aggrieved By Confirmation Of Addition Of Rs.60.42

For Appellant: Sh. Ajay Jain (CA) a/w Shri Lovesh BansalFor Respondent: Smt. Kusum Bansal (CIT) & Shri Rajat Kumar

Section 127Section 139(1)Section 143(2)Section 143(3)Section 28

record. However, rejecting assessee’s submissions, Ld. AO added amount of Rs.60.42 Lacs as business income u/s 28 and finalized the assessment. 2.3 During first appeal, the assessee vehemently opposed impugned addition as made on extrapolation by referring to various judicial decisions holding the field. However, Ld. CIT(A) upheld

Omprakash Shrikisan Kasat, Pune vs. Income Tax Officer Ward 3(4), Pune

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

ITA 3102/PUN/2025[2013-14]Status: DisposedITAT Pune29 Jan 2026AY 2013-14

Bench: Shri Dr. Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.3102/Pun/2025 िनधा"रण वष" / Assessment Year : 2013-14 Omprakash Shrikisan Kasat, Vs. Ito, Ward-3(4), Pune. Shree Bunglow, Sneh Paradise, Ram Baug Colony, Kothrud, Pune- 411038. Pan : Abfpk3563L Appellant Respondent Assessee By : None Revenue By : Shri Ajitesh Kumar Meena Date Of Hearing : 28.01.2026 Date Of Pronouncement : 29.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 15.09.2025 Passed By Ld. Addl./Jcit(A), Mysore [‘Ld. Cit(A)’] For The Assessment Year 2013-14. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeal.

For Appellant: NoneFor Respondent: Shri Ajitesh Kumar Meena

Section 143(3)Section 14ASection 40

after hearing Ld. DR. 8. We have heard Ld. DR and perused the material available on record. In this regard, we find that the first appeal order was passed ex-parte since the assessee remained absent before Ld. CIT(A). Considering the totality of the facts of the case

Manoj Kumar, Panipat vs. Income Tax Officer, Ward -1, Panipat

In the result, appeal of the assessee is allowed

ITA 3378/DEL/2025[2018-19]Status: DisposedITAT Delhi29 Jan 2026AY 2018-19

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2018-19] Manoj Kumar Vs Ito Prop. Avitex India, Barsat Ward-1 Road, Opp.Kirpal Ashram, Panipat Panipat, Haryana-132103. Pan-Aaepo2553J Appellant Respondent Assessee By Shri Suresh Kumar Gupta, Ca Revenue By Ms. Amisha S.Gutpa, Cit Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 29.01.2026 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By Assessee Against The Order Dated 27.03.2025 Passed By Ld. Pr. Commissioner Of Income Tax, Rohtak [“Ld. Pr. Cit”] U/S 263 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 24.02.2023 Passed U/S 147 R.W.S. 144B Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income On 18.10.2018, Declaring Total Income Of Inr 5,12,820/-. Based On The Available That The Assessee Had Accepted Accommodation Entries In The Form Of Bogus Purchases From M/S. Soni Textiles Of Inr 11,47,500/-, Case Was Re-Opened By Issue Of Notice U/S 148 On 29.03.2022. In Response To The Notice, Assessee Filed Return Of Income On 25.11.2022, Declaring Total Income Of Inr 5,12,820/-. Thereafter, Various Notices Were Issued From Time To Time However, Were Remained Uncompiled With. Thereafter, Ao Vide Order Dated 24.02.2023 Passed U/S 147 R.W.S. 144B Of The Act Assessed The Income Of The Assessee At Inr 16,60,320/- By Making Addition Of Alleged Bogus Purchases.

Section 147Section 148Section 15BSection 263Section 37(1)Section 69C

consideration. 6. Before us, Ld. AR submits that the AO has made the addition by holding the purchases as bogus accommodation entries against which first appeal is pending before the ld. CIT(A). As per ld. AR, the AO has taken a plausible view by disallowing the purchases

Madhav Education Trust, Mehsana vs. The Dy. CIT, Circle-1, Exmp, Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 2159/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Jan 2026AY 2018-19

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2018-19

Section 11Section 12ASection 143(1)Section 143(3)

complete scrutiny wherein the claim for deduction u/s 11 and 12 of the Act was again denied. The assessee had carried the matter in first appeal and the Ld. CIT(A) vide the impugned order had held that disallowance was made in the intimation

Income Tax Officer, Ward-1(8), Bhavnagar vs. Alinaqi Gulamabbas Bhimani, Bhavnagar

The appeal of the Revenue is treated as allowed for statistical purposes

ITA 2140/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Jan 2026AY 2018-19

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.2140/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 The Income Tax Officer Alinaqi Gulamabbas Bhimani बनाम/ Ward-1(8) Prop. Of United Steel V/S. Bhavnagar – 364 001 Corporation Nr. Bajrangdas Dada Ni Vav At Sihor Dist. Bhavnagar – 364 240 "थायी लेखा सं./Pan: Bljpb 9200 L (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Varis Isani, Advocate Revenue By : Shri Arvind Kumbhare, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 20/01/2026 घोषणा की तारीख /Date Of Pronouncement: 28/01/2026 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Shri Varis Isani, AdvocateFor Respondent: Shri Arvind Kumbhare, Sr.DR

Section 115BSection 133ASection 147Section 250Section 68

corresponding commission income paid by the assessee for obtaining the alleged accommodation entries. ITO vs. Alinaqi Gulamabbas Bhimani Asst. Year : 2018-19 4. In first appeal, the Ld. CIT(A), however, restricted the addition only to Rs.12,66,554/- being 12.5% of the total addition of Rs.1

K Vinothkumar, Coimbatore vs. ITO, Ncw-2(4), Coimbatore

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

ITA 2776/CHNY/2025[2017-18]Status: DisposedITAT Chennai28 Jan 2026AY 2017-18

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.S. Kaarthick, AdvFor Respondent: Ms.R. Anitha, Addl.CIT

confirming addition of ₹2.84 Crs, in his hands also tantamount to double addition. Further, he brought to our notice that the first appeal against the assessment order dated 30.03.2022 in the case of Mr. S.Mukeshkumar [PAN: BVMPM 5064 L] is still pending before the Ld.CIT(A)/NFAC and therefore prayed ... hands of Mr. S.Mukeshkumar as well as the assessee. In the light of the aforesaid facts, the assessee’s plea that since the first appeal of Shri S.Mukeshkumar is still pending before the Ld.CIT(A), the assessee’s appeal may be set aside back to the file of the Ld.CIT

Uttar Bahrtiiya Education Society, Mumbai vs. Income Tax Officer, Mumbai

In the result, appeal filed by the assessee is dismissed

ITA 7652/MUM/2025[2019-2020]Status: DisposedITAT Mumbai28 Jan 2026AY 2019-2020

Bench: Shri Sandeep Gosain & Shri Bijayananda Pruseth

Section 10Section 250

Uttar Bhartiya Education Society “1 Condonation refused without justification: The Ld. CITA erred in refusing to condone the delay in filing the first appeal despite a bona fide and reasonable explanation non-receipt of physical notices and reliance on professional advice, supported by affidavits and contemporaneous material. The delay deserves ... under: “1. Condonation refused without justification. The Ld. CITA erred in refusing to condone the delay in filing the first appeal despite a bona fide and reasonable explanation non-receipt of physical notices and reliance on professional advice, supported by affidavits and contemporaneous material. The delay deserves to be condoned

Uttar Bhartiya Education Society, Mumbai vs. Income Tax Officer, Mumbai

In the result, appeal filed by the assessee is dismissed

ITA 7651/MUM/2025[2018-2019]Status: DisposedITAT Mumbai28 Jan 2026AY 2018-2019

Bench: Shri Sandeep Gosain & Shri Bijayananda Pruseth

Section 10Section 250

Premji Bhurlal Gala, Mumbai vs. Addl CIT Rang 24(1), Mumbai

In the result, Assessee’s appeal is allowed

ITA 6596/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Jan 2026AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Prusethassessment Year: 2016-17 Premji Bhurlal Gala Addl. Cit Range 24(1), B-301, Water Ford, Cd Mumbai Barfiwala Road Juhu Fally Kautilya Bhavan, C-41 To C- Vs. Andheri West, Mumbai - 43, G Block, Bandra Kurla 400058 Complex, Bandra (E) Mumbai – 400051 (Appellant) (Respondent) Present For: Assessee By : Shri Vinod Kumar Bindal & Satish Kumar, Ld. A. Rs. Revenue By : Shri Virabhadra Mahajan, Sr. D.R. Date Of Hearing : 09.12.2025 Date Of Pronouncement : 28.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 23.09.2025, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2016-17. 2. In The Instant Case, The Case Of The Assessee Was Reopened Under Section 147 Of The Act, On The Basis Of Search & Survey Action Under Section 132 Of The Act Carried Out In The Case Of M/S. Evergreen Enterprises, Wherein The Statement Of The Partner In M/S. Evergreen Enterprises, Mr. Nilesh Bharani Was Recorded Under Section 132(4) Of The Act, Unearthing An Undisclosed Activity, 2 Premji Bhurlal Gala

For Appellant: Shri Vinod Kumar Bindal & SatishFor Respondent: Shri Virabhadra Mahajan, SR. D.R

Section 132Section 132(4)Section 142(1)Section 143(2)Section 147Section 148Section 250Section 269SSection 271Section 271D

section. 11. The Assessee being aggrieved challenged the said penalty being imposed by the Assessing Officer vide penalty order dated 26.09.2022 by filing the first appeal before the Ld. Commissioner. 12. Before the Ld. Commissioner the Assessee made following submissions: 3. Submission of the Appellant: The submission made

Rajput Mohammadmuntasim Tashbihuddin, Delhi vs. Income Tax Officer, Delhi

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

ITA 3958/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Jan 2026AY 2018-19

Bench: Ms. Madhumita Roy & Shri Brajesh Kumar Singh

Section 139(1)Section 142(1)Section 147Section 272A(1)(d)Section 69A

mandatory CBDT guidelines (non-supply of sanction u/s 151 along with notice us 148). 3.That assessment order passed u/s 147/144B dated 17.03.2023 and impugned first appeal order dated 21.04.2025 are both invalid being made without requisite/valid sanction u/s 151 of 1961 Act. 4. That assessment order passed u/s 147/1448 dated ... 147/144B is valid, lawful, and sustainable in the eyes of law. Ground No. 3: That assessment order passed u/s 147/144B dated 17.03.2023 and impugned first appeal order dated 21.04.2025 are both invalid being made without requisite/valid sanction u/s 151 of 1:961 Act. Comments: The requisite approval under section

Turf Estate Jv, Mumbai vs. Assisstant Commissioner of Income Tax Circle - 20(3), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 6923/MUM/2024[2017-18]Status: DisposedITAT Mumbai27 Jan 2026AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri Ravi Ganatra, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR

Section 143(3)Section 195Section 40Section 90A

Double Tax Avoidance Agreements (DTAA) to each of the payee. Ld. CIT(A) upheld the disallowance made by the ld. Assessing Officer in the first appeal filed by the assessee. Aggrieved, assessee is in appeal before the Tribunal. 5. We have heard both the parties and perused the material

Shreyas Paradkar, Mira Road vs. ITO 1(1) Thane, Thane

In the result, Assessee’s appeal is dismissed

ITA 4721/MUM/2025[2023-2024]Status: DisposedITAT Mumbai23 Jan 2026AY 2023-2024

Bench: Shri Narender Kumar Choudhryassessment Year: 2023-24 Shreyas Paradkar (Individual), Ito Range 1(1), C/O Ca Rahul Godbole & Ashar I.T. Park, 6Th Floor, Vs. Associates, 204, Spectra, Kothrud, Road No. 162, Wagle Indl. Pune – 411038. Estate, Pan- Cvzpp8788C Thane – 400604. (Appellant) (Respondent) Present For: Assessee By : Shir H.V. Datar, (Virtually Present) Revenue By : Shri Vinod Kumar V., Sr. D.R. Date Of Hearing : 20.11.2025 Date Of Pronouncement : 23.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 09.06.2025, Impugned Herein, Passed By Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2023-24. 2. In The Instant Case, The Assessee Has Claimed That He Opted For The New Tax Regime While Filing His Return Of Income On 25Th July 2023 By Entering All The Data On The Income-Tax Website. On Selecting The New Tax Regime, The Income-Tax Website Showed Tax Payable At ₹5,000 After Giving Credit For Tds & Therefore, The Assessee Paid The Respective Tax Payable & Submitted The Itr. The Assessee, On The Last Page Of The Itr, Computed The Tax As Per The New Regime, But Somehow, On The First Page Of The Return Of Income Filed, It Is Shown That The Assessee Did Not Opt For The New Tax Regime. This Was A Glitch On The Website, But Somehow, The Return Filed By The Assessee Was Processed Vide Intimation Dated 29.12.2023, Whereby The Taxable Income And/Or Return Filed By The Assessee Was Computed As Per The Old Regime & Not As Per The New Tax Regime Mainly For The Reason That The Assessee Failed To File The Relevant 2 Shreyas Paradkar (Individual)

For Appellant: Shir H.V. Datar, (Virtually Present)For Respondent: Shri Vinod Kumar V., SR. D.R

Section 115BSection 139(1)Section 143(1)Section 154Section 250

assessee under the new tax regime, however, of no avail. Therefore, the assessee challenged the said intimation dated 29.12.2023 by filing a first appeal before the Ld. Commissioner (Appeals), who dismissed the appeal of the assessee by observing and holding as under: - 5.1.3 The Finance Act 2020 has inserted

Sangam Traders 60-Golden Avenue Saili Road Pathankot, Pathankot vs. Income Tax Officer Ward 1 Pathankot Saili Road Pathankot, Pathankot

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

ITA 706/ASR/2024[2020-2021]Status: DisposedITAT Amritsar22 Jan 2026AY 2020-2021

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. P. N. Arora, Adv

Section 144Section 249(3)Section 250Section 68

eight) grounds of appeal in Form No. 36 challenging the addition of Rs. 10.76 crores u/s 144 of the Act and sustained and in first appeal, the main grievance of the assessee is that the ld. first appellate authority has dismissed the appeal without admitting the same for adjudication

Amarjit Singh, Prop Prince Engineers vs. Income Tax Officer, Jalandhar

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

ITA 325/ASR/2023[2017-18]Status: HeardITAT Amritsar22 Jan 2026AY 2017-18

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta(Physical Hearing) I.T.A. No. 325/Asr/2023 Assessment Year: 2017-18 Amarjit Singh, Prop. Prince Vs. Ito, Ward-2(1), Engineers, 411, Kalia Colony, Jalandhar. Focal Point Punjab. [Pan:-Aohps4382L] (Appellant) (Respondent) Appellant By None. Sh. Charan Dass, Sr. Dr Respondent By Date Of Hearing 19.01.2026 Date Of Pronouncement 22.01.2026

Section 142(1)Section 144Section 250Section 69A

preferred by the assessee relating to a single issue pertaining to an addition of Rs. Ten lakhs (Rs.10,00,000/-), u/s 69A sustained in first appeal. 3. The assessee filed an application before the bench, seeking time for furnishing of additional documentary evidences in support of which he proposes ... illness of his accountant. 5. The assessment completed with an addition of Rs. Ten lakhs u/s 69A of the Act was challenged in first appeal, where the assessee explained the cash deposit to have been sourced out of opening cash balance available as on the first day of April