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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

Bona Terra Greenhouses LLP, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 6(2), Mumbai

In the result, Assessee’s appeal in ITA No

ITA 2115/MUM/2025[2015-16]Status: DisposedITAT Mumbai20 Nov 2025AY 2015-16

Bench: Shri Om Prakash Kant & Shri Narender Kumar Choudhry

For Appellant: Shri Ajay R. Singh, Ld. AdvocateFor Respondent: Shri Satyaprakash R. Singh, Ld. CIT-DR
Section 132(1)Section 143(1)Section 153ASection 250Section 68

claimed by the Assessee. 8. The Assessee, being aggrieved, with the said additions and decision of the AO vide assessment order, by filing first appeal before the Ld. Commissioner raised various issues, including challenging the additions being based on no incriminating material found during the course of search proceedings u/sec

Bona Terra Greenhouses LLP, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 6(2), Mumbai

In the result, Assessee’s appeal in ITA No

ITA 2114/MUM/2025[2014-15]Status: DisposedITAT Mumbai20 Nov 2025AY 2014-15

Bench: Shri Om Prakash Kant & Shri Narender Kumar Choudhry

For Appellant: Shri Ajay R. Singh, Ld. AdvocateFor Respondent: Shri Satyaprakash R. Singh, Ld. CIT-DR
Section 132(1)Section 143(1)Section 153ASection 250Section 68

claimed by the Assessee. 8. The Assessee, being aggrieved, with the said additions and decision of the AO vide assessment order, by filing first appeal before the Ld. Commissioner raised various issues, including challenging the additions being based on no incriminating material found during the course of search proceedings u/sec

Bona Terra Greenhouses LLP, Mumbai vs. Assistant Commissioner of Income Tax Central Circle 6(2), Mumbai

In the result, Assessee’s appeal in ITA No

ITA 2089/MUM/2025[2013-14]Status: DisposedITAT Mumbai20 Nov 2025AY 2013-14

Bench: Shri Om Prakash Kant & Shri Narender Kumar Choudhry

For Appellant: Shri Ajay R. Singh, Ld. AdvocateFor Respondent: Shri Satyaprakash R. Singh, Ld. CIT-DR
Section 132(1)Section 143(1)Section 153ASection 250Section 68

claimed by the Assessee. 8. The Assessee, being aggrieved, with the said additions and decision of the AO vide assessment order, by filing first appeal before the Ld. Commissioner raised various issues, including challenging the additions being based on no incriminating material found during the course of search proceedings u/sec

Dori Lal Verma, Mathura vs. Income Tax Officer 1(3)(1) Mathura, Mathura

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

ITA 212/AGR/2025[2011-12]Status: DisposedITAT Agra19 Nov 2025AY 2011-12

Bench: Shri M. Balaganesh(Through Virtual Hearing) Dori Lal Verma, Vs. Income Tax Officer, C-42, Natwar Nagar, Ward-1(3)(1), Dhaulipyau, Mathura Mathura (Appellant) (Respondent) Pan: Afhpv2938L Assessee By : Shri Rajendra Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 19/11/2025

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR
Section 143(3)Section 147Section 69

assessment resulted in framing of an addition of Rs 15 lakhs as unexplained income under section 69 of the Act. The assessee preferred first appeal aggrieved by the order of assessment. On perusal of the order of the ld NFAC, I find that the ld NFAC had decided the issue

Anita Rani W/O Sh. Rajender Singh, Cheeka Guhla, Kaithal vs. Income Tax Officer, Ward-1, Kaithal

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

ITA 781/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh19 Nov 2025AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member)

For Appellant: Shri Navdeep Monga, AdvocateFor Respondent: Shri Prem Singh, Addl. CIT, Sr. DR
Section 144Section 148Section 234ASection 250Section 69

whereby the Ld. CIT(A) dismissed the appeal in limine on account of delay of 250 days in filing the first appeal. 2. In the present appeal Assessee has raised the following grounds: (i) That on the law, facts and in the circumstances of the case

Kalpana Ravish Maru, Malegaon vs. Income Tax Officer, Ward 1, Malegaon

In the result, appeal of the Assessee is allowed for

ITA 1724/PUN/2025[2015-16]Status: DisposedITAT Pune19 Nov 2025AY 2015-16

Bench: Shri Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Dhiraj Dandgaval, CAFor Respondent: Shri Uodol Raj Singh, DR
Section 144Section 147Section 148Section 250Section 250(6)

decide the ground which did not arise from the impugned order passed by the first appellate authority irrespective of such ground was raised in first appeal or not. However, since the legal issue goes to the root cause to the impugned additions, we in the light of the judgment

Touch Tone Teleservices, Hyderabad vs. ITO., Ward-4(1), Hyderabad

ITA 987/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Nov 2025AY 2017-18

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No. 987/Hyd/2025 (निर्धारण वर्ा/Assessment Year: 2017-18) Touch Tone Teleservices, Vs. Income Tax Officer, H. No. 3-6-550/4, 1St Floor, Ward-4(1), Street No.7, Himayatnagar, Hyderabad. Hyderabad. Pan: Aacft5196N (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Sri S. Rama Rao, Advocate रधजस् व द्वधरध/Revenue By: Sri Gurpreet Singh, Sr.Ar सुिवधई की तधरीख/Date Of Hearing: 16/10/2025 घोर्णध की तधरीख/Date Of 19/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 27/02/2025, Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 27/12/2019. The Assessee Firm Has Assailed The Impugned Order On The Following Grounds Of Appeal:

For Appellant: Sri S. Rama Rao, AdvocateFor Respondent: Sri Gurpreet Singh, Sr.AR
Section 114Section 143(2)Section 143(3)Section 145(3)

respond 3. 23/09/2024 08/10/2024 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 from the appellant during course of this appellate proceeding till date. In view of the facts and circumstances mentioned hereinabove

Vissanji A 1 Friends Co-Operative Housing Society Ltd., Mumbai vs. ITO, Ward 20(3)(1), Mumbai

ITA 4801/MUM/2025[2015-16]Status: DisposedITAT Mumbai19 Nov 2025AY 2015-16

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Vishwas Mehendale (Virtually), CAFor Respondent: Smt. Smitha V. Nair, Sr. DR
Section 143(1)Section 80ASection 80P(2)(d)

this return, after disallowing the claim of deduction u/s.80P(2)(d) of Rs.1,54,008/-, a demand of Rs.60,850/- was raised. Assessee moved first appeal before the Ld. CIT(A) by filling Form No. 35 with delay of seven years and one months for which we have already narrated ... noted that in all the 5 years, assessee has filed the return after the prescribed due date of filing the return. Also, first appeal filed by the assessee in all the five years has inordinate delay of several years. Further, there is a delay of 342 days in all these

Vissanji A 1 Friends Co-Operative Housing Society Ltd., Mumbai vs. ITO, Ward 20(3)(1), Mumbai

In the result, all the five appeals of the assessee are dismissed

ITA 4800/MUM/2025[2012-13]Status: DisposedITAT Mumbai19 Nov 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Vishwas Mehendale (Virtually), CAFor Respondent: Smt. Smitha V. Nair, Sr. DR
Section 1Section 143(1)Section 80Section 80A

after disallowing the claim of deduction u/s. 80P(2)(d) of Rs.1,54,008/-, a demand of Rs. 60,850/- was raised. Assessee moved first appeal before the Ld. CIT(A) by filling Form No. 35 with delay of seven years and one months for which we have already narrated ... noted that in all the 5 years, assessee has filed the return after the prescribed due date of filing the return. Also, first appeal filed by the assessee in all the five years has inordinate delay of several years. Further, there is a delay of 342 days in all these

Vissanji A 1 Friends Co-Operative Housing Society Ltd., Mumbai vs. ITO, Ward 20(3)(1), Mumbai

In the result, all the five appeals of the assessee are dismissed

ITA 4796/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Nov 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Vishwas Mehendale (Virtually), CAFor Respondent: Smt. Smitha V. Nair, Sr. DR
Section 1Section 143(1)Section 80Section 80A

after disallowing the claim of deduction u/s. 80P(2)(d) of Rs.1,54,008/-, a demand of Rs. 60,850/- was raised. Assessee moved first appeal before the Ld. CIT(A) by filling Form No. 35 with delay of seven years and one months for which we have already narrated ... noted that in all the 5 years, assessee has filed the return after the prescribed due date of filing the return. Also, first appeal filed by the assessee in all the five years has inordinate delay of several years. Further, there is a delay of 342 days in all these

Vissanji A 1 Friends Co-Operative Housing Society Ltd., Mumbai vs. ITO, Ward 20(3)(1), Mumbai

In the result, all the five appeals of the assessee are dismissed

ITA 4795/MUM/2025[2013-14]Status: DisposedITAT Mumbai19 Nov 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Vishwas Mehendale (Virtually), CAFor Respondent: Smt. Smitha V. Nair, Sr. DR
Section 1Section 143(1)Section 80Section 80A

after disallowing the claim of deduction u/s. 80P(2)(d) of Rs.1,54,008/-, a demand of Rs. 60,850/- was raised. Assessee moved first appeal before the Ld. CIT(A) by filling Form No. 35 with delay of seven years and one months for which we have already narrated ... noted that in all the 5 years, assessee has filed the return after the prescribed due date of filing the return. Also, first appeal filed by the assessee in all the five years has inordinate delay of several years. Further, there is a delay of 342 days in all these

Vissanji A 1 Friends Co-Operative Housing Society Ltd., Mumbai vs. ITO, Ward 20(3)(1), Mumbai

In the result, all the five appeals of the assessee are dismissed

ITA 4794/MUM/2025[2011-12]Status: DisposedITAT Mumbai19 Nov 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Vishwas Mehendale (Virtually), CAFor Respondent: Smt. Smitha V. Nair, Sr. DR
Section 1Section 143(1)Section 80Section 80A

after disallowing the claim of deduction u/s. 80P(2)(d) of Rs.1,54,008/-, a demand of Rs. 60,850/- was raised. Assessee moved first appeal before the Ld. CIT(A) by filling Form No. 35 with delay of seven years and one months for which we have already narrated ... noted that in all the 5 years, assessee has filed the return after the prescribed due date of filing the return. Also, first appeal filed by the assessee in all the five years has inordinate delay of several years. Further, there is a delay of 342 days in all these

Income Tax Officer Ward 2(2) Kalyan, Kalyan vs. Jaikumar Amarlalphagwani, Ulhasnagar

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

ITA 6729/MUM/2024[2018-19]Status: DisposedITAT Mumbai19 Nov 2025AY 2018-19

Bench: Shri Narender Kumar Choudhryshri Prabhash Shankarassessment Year: 2018-19 Income Tax Officer Ward Jaikumar 2(2) Kalyan Amarlalphagwani Income Tax Office Mohan Plaza Flat No. 703, 7Th Floor, Wayale Nagar Vs. Milan Palace A Wing Khemani, Nr Ruhani Satsang Hall Ulhasnagar, Mumbai- 421002 Pan: Amnpp8597Q (Appellant) (Respondent) Present For: Assessee By : Shri Sunil Makhija A/W Ms. Manisha Ghind Revenue By : Shri Leyaqat Ali Aafaqui, Sr.D.R. Date Of Hearing : 22.08.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per : Narender Kumar Choudhry:

For Appellant: Shri Sunil Makhija a/wFor Respondent: Shri Leyaqat Ali Aafaqui, Sr.D.R
Section 250Section 46A(3)

Assessee and added the same to the total income of the Assessee. 6. The Assessee being aggrieved challenged the said addition by filing first appeal before the Ld. Commissioner, who by considering the relevant documents and submissions filed before him 3 Jaikumar Amarlal Phagwani specifically, and by relying ... Revenue Department, first. We observe that from the grounds raised by the Assessee before the Ld. Commissioner it clearly appears that during the first appeal proceedings, the Assessee though filed the appeal and raised two grounds of appeal, however in the first ground has specifically mentioned as under: “Necessary documentary

Assistant Commissioer of Income Tax (OSD)/Income Tax Officer, Chandausi vs. Vinod Kumar Agarwal, Chandausi

In the result, appeal of the Revenue is allowed

ITA 3965/DEL/2025[2020-21]Status: DisposedITAT Delhi19 Nov 2025AY 2020-21

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2020-21] Acit (Osd)/Ito Vs Vinod Kumar Agarwal Near S.M.College Vinod Complex, Dispensary Chandausi Road, Dist.-Sambhal, U.P -244412 Chandausi, U.P-244412 Pan-Aaehv6315F Appellant Respondent

Section 147Section 250Section 44ASection 69A

made the addition of remaining cash of INR 95,29,405/- as unexplained. ITA No.3965/Del/2025 & C.O.-168/Del/2025 5. In first appeal, ld. CIT(A) accepted the claim of assessee of realization from old debtors before whom assessee filed their Aadhar Card and confirmations. It was further claimed that since

Jagtar Singh Brar Prop. Jagtar Singh Sadhu Singh, Bagapurana vs. Income Tax Officer, Ward 3, Moga

In the result, the penalty imposed u/s 271(1) (c) amounting to Rs

ITA 70/ASR/2025[2015-16]Status: DisposedITAT Amritsar18 Nov 2025AY 2015-16

Bench: Sh. Udayan Dasgupta & Sh. Khettra Mohan Roy

For Appellant: Sh. Abhinav Vijh, C.A
Section 133(6)Section 145(3)Section 250Section 271(1)Section 271(1)(c)Section 44A

being the alleged undisclosed truck income u/s 44AE. 7. Penalty subsequently imposed amounting to Rs. 4.18 lakhs, has been carried in first appeal and the Ld CIT (A) has dismissed the appeal by observing as follows: Observation of first appellate authority: “In the present case, estimation of profit

Surjit Singh Parmar, Jalandhar vs. Income Tax Officer, Jalandhar

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

ITA 303/ASR/2023[2017-18]Status: DisposedITAT Amritsar18 Nov 2025AY 2017-18

Bench: Sh. Udayan Dasgupta & Sh. Khettra Mohan Roy

For Appellant: Sh. Rohit Kapoor, Adv. &
Section 144Section 249(3)Section 250Section 44ASection 69A

Rs.41.01 lakhs estimated @ 10% of remaining credits in bank ( excluding SBN ) . 3 I.T.A. No. 303/Asr/2023 Assessment Year: 2017-18 5. The matter carried in first appeal has been dismissed by the Ld CIT (A), in limine, by invoking the provisions of section 249(3) of the Act , refusing to admit

Rishnoor Kaur, Ireland vs. Deputy Commissioner of Income Tax (International Taxation), Chandigarh

In the result, the appeal is allowed for statistical purposes

ITA 476/CHANDI/2025[2014-15]Status: DisposedITAT Chandigarh18 Nov 2025AY 2014-15

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ankit Dhiman, Advocate (Virtual Mode)For Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 144Section 147Section 249(3)

Assessment Year 2014-15 on the ground that the Ld. CIT(A) declined to condone the delay of 374 days in filing the first appeal and dismissed the appeal in-limine, without entering into the merits of the issues raised. The assessee has challenged this dismissal. 2. The assessment

DCIT, Chennai vs. Jagathrakshakan Srinisha, Chennai

ITA 1271/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Nov 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T
Section 131Section 132Section 143(3)Section 154Section 270A

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH, CHENNAI श्री एबी टी वर्की, न्यायिक

DCIT, Chennai vs. Jagathrakshakan Srinisha, Chennai

ITA 1264/CHNY/2025[2017]Status: DisposedITAT Chennai18 Nov 2025

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T
Section 131Section 132Section 143(3)Section 154Section 270A

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH, CHENNAI श्री एबी टी वर्की, न्यायिक

DCIT, Chennai vs. Jagathrakskan Srinisha, Chennai

In the result, the appeals filed by the Revenue in I

ITA 1253/CHNY/2025[2017-18]Status: DisposedITAT Chennai18 Nov 2025AY 2017-18

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

For Appellant: Shri. B. Ramakrishnan, FCA &For Respondent: Shri. C.N. Bipin, C.I.T
Section 131Section 132Section 143(3)Section 154Section 270A

deliberate underreporting or misreporting of income. In the present case, only a portion of the addition made was sustained in the first appeal by telescoping the drawings of earlier years coupled with the income returned. Accordingly, the ground raised by the appellant upon the levy of penalty is hereby treated