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“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
87
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
59
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
55
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
40
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
32
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
30
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
28
citing judgments

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

Judgments citing first appeal

Apurva Mukesh Thakkar, Mumbai vs. ITO Ward 41(2)(1) Mumbai, Kautiliya Bhavan

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

ITA 6367/MUM/2025[2011-12]Status: DisposedITAT Mumbai22 Jan 2026AY 2011-12

Bench: Shri Amit Shukla& Shri Makarand Vasant Mahadeokarapurva Mukesh Ito Ward 41 Thakkar (2)(1) Mumbai 11 Dr Rp Road & Ns Vs. Room No. 234 Mataji Bungalow Bldg Kautilya Bhavan Cross Road Near City C41 To C43 Block Bank Atm Mumbai Bkc Bandra East 400080 - Mumbai Mumbai 400051, Mumbai Pan/Gir No. Adspt8293K (Applicant) (Respondent) Assessee By Shriparth J. Bhatt Revenue By Shrisurendra Mohan (Sr. Dr.) Date Of Hearing 19.01.2026 Date Of Pronouncement 22.01.2026

Section 139(1)Section 144Section 148Section 250

never served upon the assessee, either electronically or through physical mode. ii. The assessee was under a bona fide belief that the first appeal was still pending, as the matter was earlier being handled by his Chartered Accountant and thereafter remained unattended due to the onset of the Covid ... pandemic. iii. The assessee came to know about the dismissal of the first appeal only in March 2024, when coercive recovery proceedings were initiated and the demand notice was was engaged. iv. Immediately upon acquiring knowledge of the impugned order, the assessee took steps to obtain copies

Multi Venture Infotech Pvt Ltd, Mumbai vs. National Faceless Appeal Centre, New Delhi

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

ITA 3677/MUM/2025[2014-15]Status: DisposedITAT Mumbai22 Jan 2026AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Prusethassessment Year: 2014-15 Multi Venture Infotech Pvt. National Faceless Appeal Ltd., Centre 404 Bldg No. 8A Damodar Park, National Faceless Appeal Vs. Ghatkopar West, Mumbai, Centre, 245-A, North Block, Maharashtra – 400086 New Delhi, Delhi - 110001 Pan : Aaacm9718L (Appellant) (Respondent) Present For: Assessee By : Shri Tejas Sodha, Ld. A.R. Revenue By : Shri Virabhadra S. Mahajan, Sr.D.R. Date Of Hearing : 17.12.2025 Date Of Pronouncement : 22.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 12.04.2023, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac) /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. 2014-15. 2. In The Instant Case, The Assessing Officer Vide Assessment Order Dated 24.05.2023 Under Section 147 R.W.S. 144 (B) Of The Act Has Made The Additions / Disallowances Of Rs. 2,03,00,000/- & Rs. 96,11,642/- Respectively On Account Of Unexplained Cash Credit Under Section 68 Of The Act & 2 Multi Venture Infotech Pvt. Ltd. Disallowance Of Loss In Derivative Transaction (Variation Proposed).

For Appellant: Shri Tejas Sodha, Ld. A.RFor Respondent: Shri Virabhadra S. Mahajan, SR.D.R
Section 147Section 250Section 68

Section 68 of the Act and 2 Multi Venture Infotech Pvt. Ltd. disallowance of loss in derivative transaction (variation proposed). 3. The Assessee filed first appeal before the Ld. Commissioner, challenging the addition of Rs. 203,00,000/- under Section 68 of the Act but not the disallowance

Murari Lal Harish Chand Jaiswal Pvt Ltd, Delhi vs. DCIT, Central Circle-31, Delhi

In the result, appeal of the assessee is allowed

ITA 203/DEL/2025[2018-19]Status: DisposedITAT Delhi22 Jan 2026AY 2018-19

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2018-19] Murari Lal Harish Chand Vs Dcit Jaiswal Pvt. Ltd., 6043, Central Circle-31, Naya Bans, Chandni Delhi Chowk, Delhi-110006. Pan-Aaacm6428P Appellant Respondent Appellant By Shri Pranav Yadav, Adv. Respondent By Shri Jitender Singh, Cit Dr Date Of Hearing 26.11.2025 Date Of Pronouncement 22.01.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 19.12.2024 Passed By Ld. Commissioner Of Income Tax (A)-30, New Delhi [“Ld.Cit(A)”] In Appeal No.30/10268/2017-18 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 22.12.2021 Passed U/S 153A Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That Assessee Company Is A Firm, Engaged In The Business Of Manufacture Of Tobacco Products & Derived Income From Profits & Gains From Business & From Capital Gain/Loss & Filed Its Return Of Income On 28.09.2018, Declaring Income Of Inr 1,09,82,630/-. The Case Was Selected For Scrutiny Under Cass For Following Two Issues:- (I) Icds Compliance & Adjustment (Ii) Income U/S 56(2)(X)

Section 127Section 132Section 143(2)Section 143(3)Section 153ASection 153DSection 250Section 56(2)(x)

complete the assessment and made the additions u/s 56(2)(x) of the Act. It is further observed that Ld. CIT(A) in first appeal vide order dated 04.01.2024 annulled the said order passed u/s 143(3) of the Act. However, in the subsequent order passed u/s 153A dated

Virendra Kumar Namdev, Indore vs. CIT(A), National Faceless Appeal Centre (NFAC)

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

ITA 254/IND/2025[2013-14]Status: DisposedITAT Indore21 Jan 2026AY 2013-14

Bench: Shri Siddhartha Nautiyal (Judicial Member), Shri B.M. Biyani (Accountant Member)

For Appellant: Shri Pranay Goyal, C.AFor Respondent: Shri Ashish Porwal, Sr. D.R
Section 144BSection 147

been passed without considering the fact that the appellant had duly complied with assessment proceedings, however he was not able to participate in the first appeal proceedings. 2) That, the Ld. CIT(A) erred to dismiss the appeal filed before him, ignoring the adjournment application filed by the appellant, such

Sahirbahi Kothiya, Ahmedabad vs. The ITO, Ward-7(2)(1), Ahmedabad

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

ITA 2166/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad21 Jan 2026AY 2019-20

Bench: Cit(A).

Section 69Section 69ASection 69C

please be quashed and set aside, condone the delay and allow the appeal. 2. Delay of 12 days caused in filing the first appeal may please be condone as appellant has explained sufficient and reasonable caused. 3. Addition made of Rs. 1,62,62,400/- as unexplained investment

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 737/CHNY/2022[2013-2014]Status: DisposedITAT Chennai21 Jan 2026AY 2013-2014

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

wise profit for assessment from the said project as follows: :-19-: I.T.A. Nos.:727 to 730/Chny/2022 & I.T.A.Nos.732 to 737 /Chny/2022 49. In the first appeal, the Assessee questioned the adoption of the purchase price by resorting to estimation as well question the selling price adopted

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 736/CHNY/2022[2012-2013]Status: DisposedITAT Chennai21 Jan 2026AY 2012-2013

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

wise profit for assessment from the said project as follows: :-19-: I.T.A. Nos.:727 to 730/Chny/2022 & I.T.A.Nos.732 to 737 /Chny/2022 49. In the first appeal, the Assessee questioned the adoption of the purchase price by resorting to estimation as well question the selling price adopted

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 735/CHNY/2022[2011-2012]Status: DisposedITAT Chennai21 Jan 2026AY 2011-2012

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

wise profit for assessment from the said project as follows: :-19-: I.T.A. Nos.:727 to 730/Chny/2022 & I.T.A.Nos.732 to 737 /Chny/2022 49. In the first appeal, the Assessee questioned the adoption of the purchase price by resorting to estimation as well question the selling price adopted

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 734/CHNY/2022[2010-2011]Status: DisposedITAT Chennai21 Jan 2026AY 2010-2011

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

wise profit for assessment from the said project as follows: :-19-: I.T.A. Nos.:727 to 730/Chny/2022 & I.T.A.Nos.732 to 737 /Chny/2022 49. In the first appeal, the Assessee questioned the adoption of the purchase price by resorting to estimation as well question the selling price adopted

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 733/CHNY/2022[2009-2010]Status: DisposedITAT Chennai21 Jan 2026AY 2009-2010

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

wise profit for assessment from the said project as follows: :-19-: I.T.A. Nos.:727 to 730/Chny/2022 & I.T.A.Nos.732 to 737 /Chny/2022 49. In the first appeal, the Assessee questioned the adoption of the purchase price by resorting to estimation as well question the selling price adopted

M/S Vcv Builders Private Limited, Theni vs. CIT (A)- 19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 732/CHNY/2022[2008-2009]Status: DisposedITAT Chennai21 Jan 2026AY 2008-2009

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

wise profit for assessment from the said project as follows: :-19-: I.T.A. Nos.:727 to 730/Chny/2022 & I.T.A.Nos.732 to 737 /Chny/2022 49. In the first appeal, the Assessee questioned the adoption of the purchase price by resorting to estimation as well question the selling price adopted

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 730/CHNY/2022[2012-2013]Status: DisposedITAT Chennai21 Jan 2026AY 2012-2013

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

wise profit for assessment from the said project as follows: :-19-: I.T.A. Nos.:727 to 730/Chny/2022 & I.T.A.Nos.732 to 737 /Chny/2022 49. In the first appeal, the Assessee questioned the adoption of the purchase price by resorting to estimation as well question the selling price adopted

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 729/CHNY/2022[2011-2012]Status: DisposedITAT Chennai21 Jan 2026AY 2011-2012

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

wise profit for assessment from the said project as follows: :-19-: I.T.A. Nos.:727 to 730/Chny/2022 & I.T.A.Nos.732 to 737 /Chny/2022 49. In the first appeal, the Assessee questioned the adoption of the purchase price by resorting to estimation as well question the selling price adopted

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 728/CHNY/2022[2010-2011]Status: DisposedITAT Chennai21 Jan 2026AY 2010-2011

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

wise profit for assessment from the said project as follows: :-19-: I.T.A. Nos.:727 to 730/Chny/2022 & I.T.A.Nos.732 to 737 /Chny/2022 49. In the first appeal, the Assessee questioned the adoption of the purchase price by resorting to estimation as well question the selling price adopted

Mr.V.Churchil, Theni vs. CIT(A)-19, Chennai

In the result, all the four appeals filed by the individual in ITA Nos

ITA 727/CHNY/2022[2009-2010]Status: DisposedITAT Chennai21 Jan 2026AY 2009-2010

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:727 To 730/Chny/2022 "नधा&रण वष& / Assessment Years: 2009 -10 To 2012-13 V. Churchil, Acit, 412, Electronic City-1, Vs. Central Circle -2, Koduvilarpatti, Madurai. Theni – 625 531. [Pan: Afypc-8311-D] (अपीलाथ(/Appellant) ()*यथ(/Respondent)

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 153ASection 234B

wise profit for assessment from the said project as follows: :-19-: I.T.A. Nos.:727 to 730/Chny/2022 & I.T.A.Nos.732 to 737 /Chny/2022 49. In the first appeal, the Assessee questioned the adoption of the purchase price by resorting to estimation as well question the selling price adopted

Connect Pack LLP, Mumbai vs. Income Tax Office National Faceless Assessment Centre, Delhi

In the result, Assessee’s appeal is allowed for statistical purposes

ITA 7102/MUM/2025[2017-18]Status: DisposedITAT Mumbai21 Jan 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Jagadishassessment Year: 2017-18 Connect Pack Llp, Income Tax Office Office No.4 Second Floor, Naitonal Faceless Washington Plaza, 269 Vs. Assessment Centre, Topiwala Road, Goregawan, Delhi – 110001. Mumbai – 400062. Pan – Aakfc2777Q. (Appellant) (Respondent) Present For: Assessee By : Shri Shailendra Singh Solanki, Ld. A.R. Revenue By : Shri Virabhadra Mahajan, Ld. Sr. D.R. Date Of Hearing : 05.01.2026 Date Of Pronouncement : 21.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 27.09.2025, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/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. 2017-18. 2. In The Instant Case, The Assessing Officer, Vide Assessment Order Dated 10.05.2023 Under Section 147 R.W.S. 144B Of The Act, Has Made An Addition Of Rs.36,50,000/- As Unexplained Cash Deposit Under Section 68 Of The Act. 2 Connect Pack Llp

For Appellant: Shri Shailendra Singh Solanki, Ld. A.RFor Respondent: Shri Virabhadra Mahajan, Ld. SR. D.R
Section 147Section 249Section 250Section 68

cash deposit under Section 68 of the Act. 2 Connect Pack LLP 3. The Assessee being aggrieved challenged the said addition by filing the first appeal before the Ld. Commissioner, however, with the delay of 510 days in filing the same. The Assessee before the Ld. Commissioner in respect ... sworn affidavit. 4. The Ld. Commissioner though considered the aforesaid explanation of the Assesse qua condonation of delay of 510 days in filing the first appeal before him, however, declined to entertain the same, on the ground that the Assessee has not discharged the onus of “sufficient cause” within

M/S. Nucleus Fincons Pvt Ltd, Mumbai vs. ITO Ward 15(2)(2), Mumbai

In the result, the Assessee’s appeal is allowed for statistical purposes

ITA 5025/MUM/2025[2012-13]Status: DisposedITAT Mumbai21 Jan 2026AY 2012-13

Bench: Shri Narender Kumar Choudhryassessment Year: 2012-13 M/S. Nucleus Fincons Pvt. Ito 15(2) (2), Ltd. Aaykar Bhavan, M.K. Road, (Since Strike Off By Roc From Mumbai – 400020. 24/02/2017 Through Erstwhile Director, Kishore Patki), Vs. 503, Ankita Apartments, Opp. Gymkhana, Navghar Road, Mulund, Mumbai – 400081. Pan – Aabc6734A (Appellant) (Respondent) Present For: Assessee By : Shri Nishit Gandhi, Ld. A.R. Revenue By : Shri A.M.K. Mahadevan, Sr. D.R. Date Of Hearing : 20.11.2025 Date Of Pronouncement : 21.01.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 22.09.2023, Impugned Herein, Passed By The National Faceless Appeal Centre (Nfac)/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. 2012-13. 2. In The Instant Case, The Ao Vide Assessment Order Dated 27.11.2019 Under Section 147 R.W.S. 147 Of The Act Has Made The Additions Of Rs.7,00,000,/- & Rs.19,88,290/- Respectively As Unexplained Income Under Section 68 Of The Act & Estimation Of Income @ 1 + 1 % Of Rs.9,94,14,500/- On Credit & Debit Side. 2 M/S. Nucleus Fincons Pvt. Ltd

For Appellant: Shri Nishit Gandhi, Ld. A.RFor Respondent: Shri A.M.K. Mahadevan, Sr. D.R
Section 147Section 250Section 68

debit side. 2 M/s. Nucleus Fincons Pvt. Ltd 3. The Assessee being aggrieved against the additions, as well as the assessment order, filed first appeal before the Ld. Commissioner challenging the same however, despite issuing various notices eventually made no compliance and/or filed no submissions and documents. Therefore

Sapna Jain, New Delhi vs. The Joint Commissioner of Income Tax Range-63, Delhi

The appeal of the assessee is dismissed

ITA 6269/DEL/2025[2017-2018]Status: DisposedITAT Delhi21 Jan 2026AY 2017-2018

Bench: Shri Mahavir Singh, Hon’Ble Vice- & Smt. Renu Jauhri, Hon’Ble

For Appellant: Shri S. M. Bhardwaj, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 250Section 269SSection 271Section 271D

order dated 05.08.2025 in the Appeal No. CIT(A), Delhi- 20/10309/2019-20. 2. The assessee has raised following grounds of Appeal: “1. The First Appeal Order and Assessment Order passed are illegal and against the facts of the case. 1 | P a g e 6269_DEL_2025_Sapna Jain vs JCIT

DCIT Central Circle 1 Delhi, Delhi vs. Sahara India Financial Corporation Ltd, Lucknow

ITA 4679/DEL/2025[2010-11]Status: DisposedITAT Delhi21 Jan 2026AY 2010-11
Section 142Section 250Section 269SSection 271D

case of Sundaram & Co. (supra), the assessment was reopened under section 147 of the Act and certain disallowances were made. The assessee preferred first appeal, challenging both the validity of reopening as well as the merits of the case. The CIT(A) came to the conclusion that the assessee

Hasbro Sa, Switzerland vs. Deputy Commissioner of Income Tax (International Tax), Circle 1(1)(1), Delhi, New Delhi

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

ITA 2842/DEL/2025[2020-21]Status: DisposedITAT Delhi21 Jan 2026AY 2020-21

Bench: Shri Ramit Kochar & Shri Raj Kumar Chauhan

Section 139(4)Section 143(1)Section 154Section 199Section 250

appropriate time and no reasons are given for non-filing of the additional evidence even before the Ld. CIT(A) in the first appeal and Ld. DR, on behalf of the revenue, has therefore, opposed to admit the additional evidence under Rule 29 of the Income Tax (Appellate Tribunal) Rules