“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

Ashok Kumar Khathuria, 105 Kranti Kriplani Nagar vs. CIT(A), Delhi

Appeal is allowed for statistical purpose

ITA 230/IND/2025[2013-2014]Status: DisposedITAT Indore24 Dec 2025AY 2013-2014

Bench: Shri Siddhartha Nautiyal

Section 144Section 147Section 251Section 50C

Shri Ashish Porwal, Sr. DR Date of Hearing 17.12.2025 Date of Pronouncement 24.12.2025 smez1/O RDER Per B.M. Biyani, A.M.: Feeling aggrieved by order of first-appeal bearing DIN: ITBA/NFAC/S/250/2024-25/1071832325(1) dated 02.01.2025 passed by learned Commissioner of Income-Tax (Appeals)-NFAC, Delhi [“CIT(A)”] which in turn arises ... appeal is dismissed.” Thus, in Para 5, Ld. CIT(A) has rejected adjournment application filed by assessee and proceeded to decide assessee’s first-appeal. Thereafter, vide Page 3 of 6 Ashok Kumar Khathuria ITA No. 230/Ind/2025 - AY 2013-14 Paras 6 & 7, the CIT(A) has dismissed assessee

Granules India Limited, Hyderabad vs. DCIT., Circle-2(1), Hyderabad

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

ITA 1295/HYD/2025[2020-21]Status: DisposedITAT Hyderabad24 Dec 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.1295/Hyd/2025 (िनधा"रण वष"/Assessment Year:2020-21) M/S. Granules India Limited, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan : Aaacg7369K Circle 2(1), Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Y.V. Bhanu Narayan Rao, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025

For Appellant: Shri Y.V. Bhanu Narayan RaoFor Respondent: Dr. Sachin Kumar, SR-DR

Section 139(1)Section 143(1)Section 143(3)Section 154Section 155(18)Section 270A

appellant, the issue of addition made by the AO in respect of ESOP expenses 1,98,06,000/- had been contested in first appeal filed vide Appeal No. NFAC/2019- 20/10182512 on 25/10/2022 has been disposed by this office in on 24/06/2025. This issue has been decided by this office

Imran Dawood Vehvaria, Mumbai vs. Ward 24(2)(1), Mumbai

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

ITA 5773/MUM/2025[2016-17]Status: DisposedITAT Mumbai24 Dec 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Prusethassessment Year: 2016-17 Imran Dawood Vehvaria, Ward 24(2)(1), D 701 Remibiz Court, Off Veera Piramal Chamber, Lal Baug, Vs. Road, Andheri, West Mumbai, Parel, Mumbai – 400012. Mumbai – 400053. Pan – Aatpv9817B (Appellant) (Respondent) Present For: Assessee By : None Revenue By : Shri Virabhadra Mahajan, Sr. D.R. Date Of Hearing : 24.12.2025 Date Of Pronouncement : 24.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 22.07.2025, 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. 2016-17. 2. On The Previous Date Of Hearing On 22.12.2025, None Was Present On Behalf Of The Assessee & Therefore, The Case Was Adjourned To Today I.E. 24.12.2025 & Notice Was Directed To Be Served Through E-Mail & Telephonically & Therefore The Assessee Served Accordingly But Still The Assessee Neither Appeared Nor Filed Any Adjournment Application, Thus, We Are Constrained To Decide This Appeal As Ex-Parte. 2 Imran Dawood Vehvaria

For Appellant: NoneFor Respondent: Shri Virabhadra Mahajan, SR. D.R

Section 147Section 250

variation in respect of unexplained expenditure and (iv) Rs.3,05,462/- being variation in respect of undisclosed rental income. 4. Though the Assessee filed first appeal before the Ld. Commissioner, however, despite issuing three notices by the Ld. Commissioner, the Assessee eventually made no compliance and therefore, the Ld. Commissioner

Jyoti Embroidery Private Limited, Mumbai vs. Income Tax Officer Ward 10(2)(1), Mumbai

In the result, assessee’s appeal is allowed

ITA 5637/MUM/2025[2013-14]Status: DisposedITAT Mumbai24 Dec 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2013-14 Jyoti Embroidery Private Income Tax Officer, Limited, Ward 10 (2)(1), V1-0 Vara’S House, 1St Aaykar Bhavan, M.K. Road, Vs. Ganeshwadi, Ground Floor, Mumbai – 400020. Near Mj Market, Zaveri Bazar, Mumbai – 400002 Pan – Aaacj 0872 G (Appellant) (Respondent) Present For: Assessee By : Shri Dharan Gandhi, Ld. Ar Revenue By : Ms. Kavitha Kaushik, Ld. Sr. Dr Date Of Hearing : 04.11.2025 Date Of Pronouncement : 24.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 28.07.2025 Impugned Herein Passed By The National Faceless Appeal Center (Ld. Commissioner Of Income Tax (Appeals) (For Short Ld. Commissioner) Under Section 250 Of The Income Tax Act, 1961 (For Short The ‘Act’) For The Ay 2013-14. 2. In The Instant Case, The Assessee Has Sold A Land To M/S. Yogeshwar Farms Private Limited For A Sale Consideration Of Rs. 2,15,00,000/- & Claimed The Long Term Capital Gain Of Rs. 1,58,00,000/- In The Return Of Income Filed On Dated 28Th September, 2013, Declaring Total Income Of Rs. 1,57,50,330/-. The Ao Considered The Said Claim Of The Assessee & Ultimately Found That The Stamp Duty Value Of The Property Is Of 2 Jyoti Embroidery Private Limited Rs.387,39,000/- & The Assessee Has Sold The Property For Rs.2,15,00,000/- I.E. Less Than The Value Adopted Or Assessed By The Valuation Authorities Of The State Government & Therefore He Vide Assessment Order Dated 25.09.2017 Under Section 143 (3) Read With Under Section 147 Of The Act, Ultimately Made The Addition Of Rs. 1,72,39,000/- Being Differential Amount Between The Stamp Duty Valuation & The Value Declared By The Assessee.

For Appellant: Shri Dharan Gandhi, Ld. ARFor Respondent: Ms. Kavitha Kaushik, Ld. SR. DR

Section 143Section 147Section 250Section 55

amount between the stamp duty valuation and the value declared by the assessee. 3. The assessee being aggrieved challenged the said addition by filing first appeal before the Ld. Commissioner and claimed that on the request of the assessee, the Ld. CIT (A) -17, Mumbai has asked

Sindhumati Ramavtar Pathak, Borivali Mumbai vs. Asst Commissioner of Income Tax 32 3 Mumbai Presently Dy C I T Circle 42 3 1 Mumbai, Mumbai

In the result, Assessee’s appeal is allowed

ITA 4914/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Dec 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Prabhash Shankar (Am) Sindhumati Ramavtar Pathak Acit-32(3) 4, Shree Bhalchandra Kripa Presently Cit, Circle Building, Daulat Nagar Road Vs. 42(3)(1) No. 3, Borivali East Kautilya Bhavan Bkc, Mumbai-400 066. Mumbai-51. Pan : Agbpp5972D Appellant Respondent

For Appellant: Shri Jitendra Singh, Ld. ADVFor Respondent: Ms. Kavitha Kaushik, Ld. DR

Section 10(38)Section 250Section 68Section 69C

stock companies. (xi) Analysis of transaction and end finding of the investigation wing. 4. The Assessee being aggrieved, challenged the said addition by filling first appeal before the Ld. Commissioner, who though affirmed the addition of Rs. 13,445,414/- under section 68 of the Act, however, deleted addition

Faisal Abdul Majeed Kazi, Mumbai vs. Income Tax Offcier 24(1)(1), Piramal Chamber

In the result, assessee‟s appeal is allowed

ITA 3790/MUM/2024[2012-13]Status: DisposedITAT Mumbai24 Dec 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Prabhash Shankar (Am) Faisal Abdul Majeed Kazi Ito-24(1)(1) E-651, B Wing, 6Th Floor Room No. 702 New Chandra Chsl, Veera Desai Road, Vs. Piramal Chambers Andheri West Lalbaug, Parel Mumbai-400 053 Mumbai-400 051. Pan : Amypk5431D Appellant Respondent Assessee By : Shri Satyaprakash Singh, Ld. Ca Revenue By : Ms. Kavitha Kaushik, Ld Dr Date Of Hearing : 06 /11/2025 Date Of : 24/12/2025 Pronouncement O R D E R Per Narender Kumar Choudhry (Jm) :-

For Appellant: Shri Satyaprakash Singh, LdFor Respondent: Ms. Kavitha Kaushik, Ld DR

Section 143(2)Section 144Section 147Section 148Section 150Section 250Section 56(2)(x)Section 68Section 69Section 80C

under section 68 and 69 of the Act. 3 Faisal Abdul Majeed Kazi 6. The assessee being aggrieved, challenged the said additions by filing first appeal before Ld. Commissioner and during the appellate proceedings, by filing some additional evidence like bank statement, purchase deed of the property, profit and loss

ACIT Circle-4(3)(1), Mumbai vs. Khadamat Integrated Solutions Pvt Ltd, Mumbai

ITA 3766/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Dec 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

Section 250

appellant had appointed a consultant, M/s Devesh K. Shah & Co (Now M/s Devesh K. Shah & Associates LLP), Chartered Accountants to handle the assessment and first appeal proceedings. Pursuant to completion of appeal proceedings by Ld. CIT(A), the consultants were not regularly associated with the appellant. Since the operations

Asia Today Ltd, Mumbai vs. ADIT (It) 2(2), Mumbai

In the result, Assessee's appeal is allowed

ITA 1403/MUM/2008[2004-2005]Status: DisposedITAT Mumbai24 Dec 2025AY 2004-2005

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2004-05 M/S. Asia Today Limited, Asst. Director Of Income C/O. Zee Entertainment Enterprises Tax (International Ltd., Vs. Taxation)-2(2), 135, Dr. Annie Besant Road, Scindia House, Worli, Mumbai – 400 018 Bellard Estate, Pan: Aabca0249F Mumbai - 400039 (Appellant) (Respondent) Present For: Assessee By : Shri Niraj Sheth, Ld. A.R. Revenue By : Shri Krishna Kumar, Ld. Sr. D.R. Date Of Hearing : 10.10.2025 Date Of Pronouncement : 24.12.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.01.2007, 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. 2004-05. 2. The Relevant Facts For Adjudication Of This Appeal Are As Under: The Assessee, Being A Foreign Telecasting Company Incorporated In Mauritius & Having Tax Residency Certificate Of Mauritius , During The Ay Under Consideration Was Engaged In The Production & Acquiring Rights Of Various Television Films Including Feature Films, As A Copy Right Owner/Holder Of Various Hindi Feature Films Produced & Censored In India, As Mentioned In Schedule ‘C’ Annexed With The ‘Agreement Of 2 M/S Asia Today Ltd. Vs Asst. Dit (Int. Taxation)-2(2)

For Appellant: Shri Niraj Sheth, Ld. A.RFor Respondent: Shri Krishna Kumar, Ld. Sr. D.R

Section 250Section 9(1)(vi)

allowing the deduction claimed to the tune of Rs.1,00,00,000/- being not liable to be taxed, before the Ld. Commissioner by filing first appeal inter alia challenging the other additions, however, could not get relief on this particular issue/aspect, as the Ld. Commissioner ultimately affirmed the decision

Satish Kumar & Sons(HUF), New Delhi vs. Ward-47(1) Jurisdictional Assessing Officer, New Delhi

In the result, the appeal of the assessee is accordingly allowed as above terms for statistical purposes

ITA 5112/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 250Section 69C

adjournment on 29.04.2025 4. 29.04.2025 14.05.2025 The appellant did not respond. There was no compliance on the part of the appellant after filing of first appeal and no communication was received form the appellant during course of this appellate proceeding till date except one adjournment dated 29.04.2025. In view

Sh. Sanjay Kumar, Dehradun vs. ITO, Ward-1(2)(3), Dehradun

In the result, Appeal of the Assessee is partly allowed for statistical

ITA 84/DDN/2025[2016-17]Status: DisposedITAT Dehradun23 Dec 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Sanjay Kumar Vs Income Tax Officer, 34 34Shankerpurhukumatpur Ward 1(2)(3), Dehradun, 248197, Uttarakhand, Uttarakhand Pan: Aaubpk4159P Appellant Respondent Assessee By Sh. Rajiv Sahini, Ca Revenue By Sh. Amar Pal Singh, Jcit, Dr Date Of Hearing 11/11/2025 Date Of Pronouncement 23/12/2025

Section 143(3)Section 69

looking after the matter passed away on 19th December, 2023 and the Assessee was not aware of the disposal of the First Appeal by the Ld. CIT(A). Further claimed that the Assessee came to know 2 Sh. Sanjay Kumar Vs. ITO about passing of the order impugned only after ... order of the Ld. CIT(A), the Ld. CIT(A) has not condoned the delay of ‘more than one year’ in filing the First Appeal and dismissed the Appeal in-limine for delay in latches at Paragraph-3 of the order impugned. However, the Ld. CIT(A) further adjudicated

Oil & Natural Gas Corporation Limited, Dehradun vs. ACIT Circl-1, Dehradun

In the result, Appeals of the Assessee are partly allowed for

ITA 143/DDN/2025[2003-04]Status: DisposedITAT Dehradun23 Dec 2025AY 2003-04

Bench: Sh. Yogesh Kumar U.S. & Sh. Manish Agarwal

For Appellant: Sh. Arijit Ghosh, AdvFor Respondent: Ms. Poonam Sharma, CIT-DR

aside the order of the Ld. CIT(A) and to remand the issue to the file of the Ld. CIT(A) to decide the first appeals on its merits. The Ld. Department's Representative has neither disputed nor objected for the above submission of the Ld. Assessee's Representative ... view of the above, as the first appeals filed by the Assessee have been dismissed on the wrong notion of the Ld. CIT(A) that the tax disputes have been settled under VSV Scheme, we set aside the impugned orders of the Ld. CIT(A) and restore the issue

Oil & Natural Gas Corporation Limited, Dehradun vs. DCIT, Circle-1, Dehradun

In the result, Appeals of the Assessee are partly allowed for

ITA 142/DDN/2025[2008-09]Status: DisposedITAT Dehradun23 Dec 2025AY 2008-09

Bench: Sh. Yogesh Kumar U.S. & Sh. Manish Agarwal

For Appellant: Sh. Arijit Ghosh, AdvFor Respondent: Ms. Poonam Sharma, CIT-DR

Income Tax Officer, Ward-1(1)(3), Dehradun, Aaykar Bhawan, Subhash Road vs. Uttarakhand Purv Sainik Kalyan Nigam Limited, Station Sub Area

In the result, appeal of the assessee is allowed

ITA 92/DDN/2024[2015-16]Status: DisposedITAT Dehradun23 Dec 2025AY 2015-16

Bench: Sh. Yogesh Kumar U.S. & Sh. Manish Agarwal

For Appellant: Sh. Tarandeep Singh, AdvFor Respondent: Sh. Amar Pal Singh, JCIT-DR

Section 10Section 139Section 139(1)Section 139(4)Section 143(3)Section 148Section 149Section 617

order of the Tribunal in Assessee’s own case for A.Y. 2014-15 (supra) while deciding 8 Uttarakhand Purv Sainik Kalyan Nigam Ltd. the First Appeal and deleted the addition made by the A.O. In the absence of any contrary material or judicial precedents brought on record by the Revenue

Sangita Gupta, Indore vs. ITO 1(2) Indore, Indore

Appeal is allowed for statistical purpose

ITA 302/IND/2025[2018-19]Status: DisposedITAT Indore23 Dec 2025AY 2018-19

Bench: Ms. Suchitra R. Kambleand**

Section 144Section 147Section 69

Date of Hearing | | | 11.12.2025 | | | Date of Pronouncement | | | 23.12.2025 | | # आदेश **/ O R D E R** ## **Per B.M. Biyani, A.M.:** Feeling aggrieved by order of first-appeal dated 29.01.2025 passed by learned Commissioner of Income-Tax (Appeals)-NFAC, Delhi ["CIT(A)"] which in turn arises out of assessment-order dated 25.03.2023 passed ... grounds mentioned in Appeal Memo (Form No. 36). - 2. Ld. AR for assessee submitted that the CIT(A) has dismissed assessee's first-appeal on the ground that there was a delay of approx. 6 months in filing of appeal by assessee. In Para 2.2 of impugned order

Jastej Gorowara, Bhopal vs. Commissioner of Income-Tax (Appeals), Delhi

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

ITA 277/IND/2025[2015-16]Status: DisposedITAT Indore23 Dec 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Ashish Porwal, Sr. DR

Section 133(6)Section 147Section 148Section 271(1)(c)Section 68

After engaging the present counsel and upon checking the e- proceeding portal, the assessee came to know for the first time that the first appeal had already been dismissed, following which immediate steps were taken to file the present appeal. The Counsel submitted that the delay was bona fide, unintentional

Jastej Gorowara, Bhopal vs. CIT(A), Delhi

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

ITA 276/IND/2025[2011-12]Status: DisposedITAT Indore23 Dec 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri Bhagirath Mal Biyani

For Appellant: Respondent byFor Respondent: Shri Ashish Porwal, Sr. DR

Section 133(6)Section 147Section 148Section 271(1)(c)Section 68

ACIT, Circle-2(1)(1), Mumbai vs. M/S Bank of India, Mumbai

In the result, appeal of the revenue is dismissed

ITA 1549/MUM/2023[2013-2014]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-2014

Bench: MS. SUCHITRA RAGHUNATH KAMBLE (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri P. J. Pardiwala, Sr. Advocate and Shri C. Naresh, CAFor Respondent: Shri Satya Pal Kumar, CIT DR

Section 10Section 115JSection 143(3)Section 14ASection 90

loss, no credit was given for the foreign taxes and the claim of the assessee was rejected by the ld. Assessing Officer. In first appeal, ld. CIT(A) denied exclusion of foreign income but held that credit for the foreign taxes can be allowed of Rs. 182.64 crores. While giving

Bank of India, Mumbai vs. The ACIT-2(1)(1), Mumbai

ITA 1397/MUM/2023[2013-14]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-14

Bench: Ms. Suchitra Raghunath Kamble & Shri Girish Agrawal

Section 10Section 115JSection 143(3)Section 14ASection 90

Kirti Tripathi, Bhopal vs. ITO 2(4), Bhopal

Appeal is allowed for statistical purpose

ITA 572/IND/2025[2011-12]Status: DisposedITAT Indore22 Dec 2025AY 2011-12

Bench: Shri Siddhartha Nautiyal & Shri B.M. Biyani

Section 139(1)Section 147Section 148

Shri Ashish Porwal, Sr. DR Date of Hearing 15.12.2025 Date of Pronouncement 22.12.2025 smez1/O RDER Per B.M. Biyani, A.M.: Feeling aggrieved by order of first-appeal dated 27.05.2024 passed by learned Commissioner of Income-Tax (Appeals)-NFAC, Delhi [“CIT(A)”] which in turn arises out of assessment-order dated ... require any repetition, were discussed during hearing. Basically, the assessee has averred in Para 5 of application that his tax consultant, who filed first-appeal to CIT(A), mentioned his own e-mail id in Form No. 35 (Appeal Memo) and all notices of hearing were sent

Pradeep Jaiswal, Sonkatch vs. ITO 1(2), Ind, Indore

In the result, the appeal is dismissed

ITA 568/IND/2025[2018-19]Status: DisposedITAT Indore22 Dec 2025AY 2018-19

Bench: Shri Siddhartha Nautiyaland**

Section 144Section 147Section 44ASection 69A

Date of Hearing | | | 16.12.2025 | | | Date of Pronouncement | | | 22.12.2025 | | # आदेश **/ O R D E R** ### **Per B.M. Biyani, A.M.:** Feeling aggrieved by order of first appeal dated 22.05.2025 passed by learned Commissioner of Income-Tax (Appeals), NFAC, Delhi ["CIT(A)"] which in turn arises out of assessment-order dated 27.03.2023 passed ... pass assessment-order u/s 144 for non-participation of assessee in assessment-proceedings. Further, the CIT(A) has also dismissed assessee's first-appeal by passing following order: #### *"5.Decision* *I have considered the grounds of appeal, statement of facts, submissions made by the Appellant, assessment order and evidences on records