“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

S R Constructions, Bangalore vs. DCIT, Central Circle-2(2), Bengaluru

ITA 637/BANG/2025[2016-17]Status: DisposedITAT Bangalore18 Nov 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Shri. Muthu Shankar,CIT(DR)(ITAT), Bangalore

Section 40A

153A by estimating income at 8% of the adjusted turnover. So, there cannot be any further additions made. 32. CIT(A), while disposing the first appeal, partially accepted the contention of the Appellant to the extent of payments made to sub- contractors in whose case cheque books were not found

S R Constructions, Bangalore vs. DCIT, Central Circle-2(2), Bangalore

ITA 636/BANG/2025[2015-16]Status: DisposedITAT Bangalore18 Nov 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan K

Section 40A

M/S. Oceanic Marketing Agencies India Ltd., Delhi vs. The Dy. Commissioner of Income Tax, (OSD), Circle 2(2), Mumbai

In the result ITA No. 4542/Mum/2025 is dismissed as

ITA 4542/MUM/2025[2008-09]Status: DisposedITAT Mumbai18 Nov 2025AY 2008-09

this date, the issue in appeal for AY 2008-09 became covered in Assessee's favour. All pending cases of first appeal migrated to faceless medium, vide S. O. 3926E. Assessee writes to counsel, seeking documents relating to AY 2007-08, and enquiring into status of AY 2008-09 appeal

Smt. Anita Rani, Jammu vs. Income Tax Officer Ward-1, Pathankot

The appeal stand allowed

ITA 246/ASR/2025[2012-13]Status: DisposedITAT Amritsar17 Nov 2025AY 2012-13

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm आयकर अपील सं. / Ita No. 246/Asr/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Smt. Anita Rani Ito Pathankot Ward बनाम/ C/O Shri J.S.Bedi Pathankot 638-A, Gandhi Nagar Punjab - 145001 Vs. Jammu – 180004 "ायी लेखा सं./Pan. Aarpr-0843-D (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : None ""थ"कीओरसे/Respondent By : Shri Charan Dass (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 12-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () Aforesaid Appeal By Assessee For Assessment Year (Ay) 1. 2012-13 Arises Out Of An Order Of Ld. Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 07-03-2024 In The Matter Of An Assessment Framed By Ld. Ao On Best Judgment Basis U/S 144 R.W.S. 147 Of The Act On 06-12-2019. The Registry Has Noted Delay Of 298 Days In The Appeal, The Condonation Of Which Has Been Sought By The Assessee On The Strength Of Condonation Petition

For Appellant: NoneFor Respondent: Shri Charan Dass (Addl. CIT) – Ld. Sr. DR

Section 144

Rs.8 Lacs and computed capital gains of Rs.2 Lacs. The assessee’s share of Rs.1 Lacs was finally added to her income. During first appeal, the assessee furnished actual computations and arrived at capital loss of Rs.1 Lacs. The computations have been extracted at Page No.5 of the impugned order

Shri Ajit Singh S/O Sh. Kartar Singh, Sheed Bhagat Singh Nagar vs. Income Tax Officer, Nawanshahar

The appeal stand allowed for statistical purposes

ITA 336/ASR/2024[2012-13]Status: DisposedITAT Amritsar17 Nov 2025AY 2012-13

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm आयकर अपील सं. / Ita No. 336/Asr/2024 (िनधा"रण वष" / Assessment Year: 2012-13) Shri Ajit Singh S/O Sh. Kartar Singh Ito बनाम/ Vill. Bharta Khurd, Nawanshahar Nawanshahar Vs. Punjab – 144518 Punjab 144516 "ायी लेखा सं./Pan. Ejtps-6081-P (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : None ""थ"कीओरसे/Respondent By : Shri Charan Dass (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 13-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 17/11/2025

For Appellant: NoneFor Respondent: Shri Charan Dass (Addl. CIT) – Ld. Sr. DR

Section 143(3)

cash deposit of Rs.38.15 Lacs for want of sufficient documentary evidences from the assessee, The assessee failed to make any effective representation during first appeal and accordingly, the assessment was confirmed against which the assessee is in further appeal before us. The assessee, in the paper-book, has placed various

Nazrul Islam, Nalbari vs. Assessing Officer, Nalbari

Appeal is allowed for statistical purposes

ITA 123/GTY/2025[2018-19]Status: DisposedITAT Guwahati17 Nov 2025AY 2018-19

Bench: The Ld. Cit(A) Was Not Condoned & The Appeal Was Not Admitted For Adjudication On The

Section 144Section 250

located in a rather remote area. His tax consultant did not guide him regarding the scrutiny proceedings and thereafter, the proceedings at first appeal stage. It was a further submission that due to lack of knowledge of tax procedure and absence of adequate advice from qualified tax practitioners, the assessee ... suffered an exparte order at assessment stage and thereafter even at first appeal stage where the delay of 227 days was not condoned by the Ld. CIT(A). It was the prayer that the assessee may be given a chance to present the facts at an appropriate level so that

Kripa Ranjan Debbarma, Agartala vs. ITO, Ward - 1, Agartala

Appeal is allowed for statistical purposes

ITA 122/GTY/2025[2013-14]Status: DisposedITAT Guwahati17 Nov 2025AY 2013-14

Bench: Your Honour Against The Rejection Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre Passed On 25.11.2024 & In The Matter Have E-Filed The Appeal In Form 35 Online With Grounds Of Appeal On 16.05.2025 & The Appeal Fee Rs. 10,000 Is Also Paid. However The Above Appeal Has Been Filed With A Delay Of 105 Days As The Appeal Was Supposed To Be Filed By 60 Days From The Date Of Order Ie. 25.11.2024 But Filed On 16.05.2025. Sir, I Am Not Able To Attend To My Regular Duties & Tasks. I Am 72 Years & Am Suffering From Depression & Various Age Related Issues. I Am Under Medical

Section 249(3)Section 250

Centre (NFAC), Delhi [hereafter “the Ld. CIT(A)]. 2.1 In this case, the main grievance of the assessee arises from the dismissal of his first appeal in limine, on the ground that the Ld. CIT(A) did not detect any “sufficient cause”, for delay as, mandated under Section ... assessee deserves a second chance to prove his bonafides before the Ld. CIT(A). Accordingly, we are condoning the delay in filing of the first appeal and setting aside the impugned order with a direction that the Ld. CIT(A) should take up fresh adjudication in this matter, after giving

Sheetal Bathla, Kota vs. Income Tax Officer Ward 1(2) Kota, Kota

In the result, appeal of the assessee is allowed

ITA 215/JPR/2025[2012-13]Status: DisposedITAT Jaipur17 Nov 2025AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shsrawan Kumar Gupta, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

Section 142(1)Section 147Section 148Section 234ASection 250

A.Y.2012-13)”. Thus the ld. AO has made the addition of Rs.89,75,000/- without invoking any provisions of the Act. In first appeal the ld. CIT(A) has confirmed the action of the ld. AO without considering the material and details available in their true perspective and sense. Hence this

Vijit Singh, Jaipur vs. ITO Ward 3(2) Jaipur, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1246/JPR/2025[2009-10]Status: DisposedITAT Jaipur17 Nov 2025AY 2009-10

For Appellant: Shri Shrawan Kumar Gupta, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

Section 147Section 234ASection 250

Funds and in absence of reply he completed the assessment by making the addition of at Rs.60,00,000/- as his undisclosed income. 2.In first appeal assessee challenged the legality, validity and proceeding u/s 147/148 and also challenged the assessment order as invalid illegal and additions. Vide GOA before ... vide his order dated 26.10.2016 passed under section 147 read with section 144 of the IT Act. However, in first appeal, the ld. CIT (A) without deciding the legal issue, set aside the ex-party assessment order for making fresh assessment, on the basis of documents submitted by the assessee

Star Ply Lam Limited, Chandigarh vs. DCIT/ACIT Cir 1(1) Chandigarh, Chandigarh

The appeal stand allowed in terms of our above order

ITA 692/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh17 Nov 2025AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No. 692/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) M/S Star Ply Lam Limited Dcit/Acit Circle 1(1) बनाम/ Sco 34, Sector 26 Chandigarh Vs. Chandigarh-160019 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aaecs-3258-F (अपीलाथ"/Appellant) (""थ" / Respondent) : Assessee By : Shri Parikshit Aggarwal (Ca) - Ld. Ar Revenue By : Shri Vinod Kumar Chaudhary (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 13-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2017-18 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 17-10- 2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 143(3) Of The Act On 31-12-2019. The Sole Grievance Of The Assessee Is Confirmation Of Addition Of Cash Deposit Of Rs.33.26 Lacs During Demonetization Period. The Registry Has Noted Delay Of 132 Days In The Appeal, The Condonation Of Which Has Been Sought By Ld. Ar On The Strength Of Condonation Petition Which Is Accompanied By Affidavit Of Assessee’S Chartered Accountant Shri Manish Goel. It Has Been Stated

For Appellant: Shri Parikshit Aggarwal (CA) - Ld. ARFor Respondent: Shri Vinod Kumar Chaudhary (Addl. CIT) – Ld. Sr. DR

Section 143(3)Section 68

granted to the assessee and the remaining cash deposit of Rs.33.26 Lacs was added u/s 68 r.w.s. 115BBE of the Act. 4. During first appeal, the assessee assailed the findings of Ld. AO and referred to various judicial decisions to support its contentions. However, the same could not find favor

Tarun Sharda Joint Commissioner of Income Tax (in Situ) Circle-I, Ludhiana vs. Sharmanji Yarns Private Limited, Ludhiana

Appeal stands dismissed

ITA 340/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh17 Nov 2025AY 2020-21

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No.340/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) Jcit (In Situ) M/S Sharmanji Yarns Pvt. Ltd. Circle-1 बनाम/ Village Lakhowal Road Aaykar Bhawan, Rishi Nagar Kohara, Jandiali Vs. Ludhiana – 141001 Ludhiana - 141112 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aahcs-6629-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.331/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2020-21) M/S Sharmanji Yarns Pvt. Ltd. Dcit-Circle-1 बनाम/ Village Lakhowal Road Aaykar Bhawan, Rishi Nagar Kohara, Jandiali Ludhiana – 141001 Vs. Ludhiana - 141112 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aahcs-6629-R (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Tej Mohan Singh (Advocate) – Ld. Ar Revenue By : Smt. Kusum Bansal (Cit)(Virtual) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 08-10-2025 घोषणाकीतारीख /Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Cross-Appeals For Assessment Year (Ay) 2020-21 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)

For Appellant: Shri Tej Mohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT)(Virtual) – Ld. DR

Section 143(3)

entire purchases of Rs.8807.02 Lacs was disallowed u/s 69C as unexplained expenditure and added to the income of the assessee. Appellate Proceedings 3.1 During first appeal, the assessee referred to various evidences to establish the genuineness of the impugned purchases. The same include purchase invoices, transport invoices, e-way bills

Sharmanji Yarns Private Limited, Ludhiana vs. Deputy Commissioner of Income Tax, Circle -1, Ludhiana

Appeal stands dismissed

ITA 331/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh17 Nov 2025AY 2020-21

For Appellant: Shri Tej Mohan Singh (Advocate) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT)(Virtual) – Ld. DR

Section 143(3)

Deputy Commissioner of Income Tax, Central Circle-1, Ludhiana vs. Nv Enterprises, Ludhiana

The appeal stands dismissed

ITA 827/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh17 Nov 2025AY 2021-22

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

For Appellant: Shri Sudhir Sehgal (Advocate) - Ld. ARFor Respondent: Shri Vinod Kumar Chaudhary (Addl. CIT) – Ld. Sr. DR

Section 131Section 143(3)Section 69A

further details. Accordingly, the amount of Rs.80.80 Lacs was added u/s 69A r.w.s. 115BBE of the act and the assessment was framed. 3. During first appeal, the assessee vehemently opposed the action of Ld. AO by way of written submissions which have already been extracted in the impugned order

Ambar Resources Private Limited, Ahmedabad vs. The ITO, Ward-1(1)(1), Ahmedabad

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

ITA 1569/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad17 Nov 2025AY 2018-19

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Varis Isani, AdvocateFor Respondent: Shri Rameshwar P Meena, Sr. DR

Section 115BSection 148Section 148ASection 249Section 69C

Asst.Year –2018-19 - 2– the appellant authority deserves to be quashed and set a side and delay cause filing the first appeal may please be condone. 2. The Lrd. Appellant Authority has erred in law in dismissing the appeal of the appellant and confirmed the order of the assessing authority

Shri Bhavnagar Dashashrimali Kanthibandh (Vaishnav) Vanik Gnati, Bhavnagar vs. The CIT(Exemption), Ahmedabad

In the result, the appeal in ITA No

ITA 135/AHD/2025[NA]Status: DisposedITAT Ahmedabad17 Nov 2025

Bench: Ms. Suchitra R. Kamble & Shri Makarand V.Mahadeokar

For Appellant: Shri Mohit Balani, AR

Section 12ASection 14Section 253(5)

above, we hold that the present appeal is rendered infructuous and is dismissed as not maintainable, being covered by the decision in the first appeal. This dismissal is, however, without prejudice to the right of the assessee to pursue all submissions and judicial precedents before the learned

Shri Bhavnagar Dashashrimali Kanthibandh (Vaishnav) Vanik Gnati, Bhavnagar vs. The CIT(Exemption), Ahmedabad

ITA 134/AHD/2025[NA]Status: DisposedITAT Ahmedabad17 Nov 2025

Bench: Ms. Suchitra R. Kamble & Shri Makarand V.Mahadeokar

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Rignesh Das, CIT-DR

Section 12ASection 14Section 253(5)

आयकर अपीलीय अधिकरण, अहमदाबाद न्यायपीठ 'C' अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD BEFORE MS. SUCHITRA R

Jayashree Sanjay Jadhav, Mumbai City vs. Assistant Commissioner of Income Tax, Circle 42 (2) (3), Mumbai

In the result, the Assessee’s appeal is allowed in the said terms

ITA 5660/MUM/2025[2017-18]Status: DisposedITAT Mumbai17 Nov 2025AY 2017-18

Bench: Shri Narender Kumar Choudhryassessment Year: 2017-18 Ms. Jayashree Sanjay Acit, Circle 42(2)(3), Jadhav, Kautalya Bhavan, Bandra H 11/703, Palm Acres Chs Ltd. Vs. Kurla Complex, Pratiksha Nagar, Sion, Bandra (East), Mumbai – 400022. Mumbai - 400051 Pan: Adgpj9973J (Appellant) (Respondent) Present For: Assessee By : Shri Anant Pai, Ld. A.R. Revenue By : Shri Vikas Chandra, Ld. Sr. D.R. Date Of Hearing : 17.11.2025 Date Of Pronouncement : 17.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 31.07.2025, Impugned Herein, Passed By Ld. Commissioner Of Income Tax (Appeals) Addl/Jcit (A) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2008-09. 2. Admittedly, The Case Of The Assessee Was Selected For Scrutiny For The Following Issues: (I) Cash Deposit In The Bank Account During Demonetization Period From 09.11.2016 To 31.12.2016. (Ii) Transactions Made In Immovable Property & (Iii) Investment Of Rs.1,50,000/- U/S 80C.

For Appellant: Shri Anant Pai, Ld. A.RFor Respondent: Shri Vikas Chandra, Ld. Sr. D.R

Section 143(3)Section 250Section 69ASection 80C

account of amount deposited by the Assessee in its bank account. 3. The Assessee though being aggrieved challenged the said addition by filing first appeal before the Ld. Commissioner, however, did not get any relief as the Ld. Commissioner vide impugned order affirmed the addition by dismissing the appeal. Thus

Belle Hospitality, Mumbai vs. ITO Ward 41(2)(1), Mumbai

In the result, Assessee’s appeal is allowed

ITA 5563/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Nov 2025AY 2012-13

Bench: Shri Narender Kumar Choudhryassessment Year: 2012-13 M/S. Belle Hospitality, Ito Ward 41(2)(1), Basement & Ground Floor, Kautilya Bhavan Filix Building Lbs Marg, Vs. Mumbai - 400051 Bhandup West, Mumbai – 400 078 Pan: Aakfb5304J (Appellant) (Respondent) Present For: Assessee By : Shri Dhaval Shah, Ld. A.R. Revenue By : Shri Praveen K. Srivastav, Ld. Sr. D.R. Date Of Hearing : 17.11.2025 Date Of Pronouncement : 17.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 28.04.2025, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax Ddl/Jcit (A) (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 This Case, The Ao Vide Order Dated 15.12.2016 U/S 143(3) Of The Act Has Made The Additions Of Rs.15,00,000/- & Rs.60,658/- For Unexplained Cash Credit/Non-Genuine Loans U/S 68 Of The Act & The Interest Paid Respectively, However, Allowed The Set Off Of Rs.10,16,395/- As Claimed By The Assessee. Subsequently, The Case Of The Assessee Was Reopened U/S 147 Of The Act By Issuing Notice Dated 23.01.2015 U/S 148 Of The Act, Which Resulted Into Passing The Reassessment Order Dated

For Appellant: Shri Dhaval Shah, Ld. A.RFor Respondent: Shri Praveen K. Srivastav, Ld. Sr. D.R

Section 115BSection 143(3)Section 147Section 148Section 250Section 68

assessment proceedings, vide order dated 15.02.2016 u/s 143(3) of the Act and therefore the reassessment order dated 04.12.2019 which was subjected to first appeal proceeding before the Ld. Commissioner and resulted in passing the impugned order, whereby the set of loss from the addition made u/s 68 has been

Singla Apparels Private Limited, Gandhi Nagar vs. Income Tax Officer, Delhi

In the result, the appeal of the assessee is allowed

ITA 5163/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Nov 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2017-18] Singla Apparels Pvt.Ltd. Vs Ito House No.17, Street No.2, Ward Shankar Nagar, Gandhi Nagar, C.R. Building, Ito Krishan Nagar, Delhi-110051. I.P.Estate Pan-Aajcs3628L New Delhi-110002 Appellant Respondent [Assessment Year : 2017-18] Singla Apparels Pvt.Ltd. Vs Ito 7244, Mahavir Gali Ward Gandhi Nagar, Delhi-1100531. C.R. Building, Ito Pan-Aajcs3628L I.P.Estate New Delhi-110002 Appellant Respondent Appellant By Shri Salil Kapoor, Adv. & Shri Utkarsa Gupta, Adv. Respondent By Shri Manish Gupta, Sr.Dr Date Of Hearing 17.11.2025 Date Of Pronouncement 17.11.2025 Order Per Manish Agarwal, Am : The Captioned Appeals Are Filed By Assessee Against The Separate Orders Dt.11.06.2024 & 12.08.2024 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.Cit(A)”] In Appeal No. Cit(A), Delhi-8/10554/2019-20 & In Appeal No. Nfac/2016-17/10058210 Respectively, Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 31.12.2019 Passed U/S 143(3) Of The Act & Penalty

Section 142(1)Section 143(2)Section 143(3)Section 156Section 250Section 271ASection 69A

which is injudicious. non-application of mind and against the factual position. 2. That Ld. CIT(A) has grossly erred in not considering the first appeal to the effect that the AO has disregarded the ground realities of business of the appellant and has made the additions on the basis ... discussion, confrontation and simply agreed to the contentions of the assessing authority and passed the order u/s 250 in haste by dismissing the first appeal. 5. That the appellant/assessee has maintained proper books of account and section 69A cannot be applied when the alleged amount is truly and fully disclosed

Singla Apparels Pvt Ltd, Gandhi Nagar vs. Income Tax Officer, Ward

In the result, the appeal of the assessee is allowed

ITA 3445/DEL/2024[2017-18]Status: DisposedITAT Delhi17 Nov 2025AY 2017-18

Section 142(1)Section 143(2)Section 143(3)Section 156Section 250Section 271ASection 69A