“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

Jajoo Rashmi Refractories Limited, Jaipur, Rajasthan vs. DCIT, Circle 4-Jaipur, Jaipur, Rajasthan

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

ITA 209/JPR/2025[2018-19]Status: DisposedITAT Jaipur06 Aug 2025AY 2018-19

For Appellant: Ms. Prabha Rana, AdvocateFor Respondent: Shri Gaurav Awasthi, JCIT-DR

Section 131Section 145Section 147Section 69C

consideration and for this addition, tax is being charged u/s 115BBE of the Act. Penalty proceedings u/s 271AAC of the Act is initiated." In first appeal, the Id. CIT(A) has confirmed the action of the AO as the assessee did not adduce any written submission or documentary evidence before

Shikha Ganeriwal, Guwahati vs. Commissioner of Income Tax (Appeals), Delhi

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

ITA 691/JPR/2023[2015-16]Status: DisposedITAT Jaipur06 Aug 2025AY 2015-16

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

For Appellant: Shri Saurav Harsh, AdvocateFor Respondent: Shri Gaurav Awasthi, JCIT-DR

Section 145(3)Section 147Section 250Section 69A

hands MS. SHIKHA GANERIWAL VS ITO, WARD 2(1), KOTA of the assessee u/s 69A r.w.s. 115BBE of the Act. In first appeal, the ld.CIT(A) has confirmed the action of the AO for the reason that the assessee did not pursue the appeal filed before

Alp Consulting Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Koramangla

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

ITA 1039/BANG/2025[2018-19]Status: DisposedITAT Bangalore06 Aug 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmedassessment Year : 2018-19

For Appellant: Shri D.N. Joshi, Ld. CAFor Respondent: Shri Balusamy N., Ld. JCIT-DR

Section 143(1)Section 143(3)Section 250

account of disallowance of deduction claimed as bad debts written off. 3. The Assessee being aggrieved though challenged the said addition by filing first appeal before the Ld. Commissioner, however despite of affording two opportunities by the Ld. Commissioner, availed none and eventually made no compliance and therefore

Mod Illva India Pvt Ltd, Delhi vs. DCIT, Circle-16(1), Delhi

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

ITA 64/DEL/2025[2014-15]Status: DisposedITAT Delhi06 Aug 2025AY 2014-15

Bench: Shri Shamim Yahya & Shri Yogesh Kumar U.S.Mod Illva India Private Vs. Assessing Officer Limited(Through Director- Dcit Circle, 16(1) Sh. Sanjay Kumar Garg), National Faceless Assessment 1513, Modi Tower, 98, Centre , Nehru Place, New Delhi Delhi Pan: Aagcm0570N Appellant Respondent Assessee By Sh. C. S. Gupta, Adv Revenue By Sh. Jitender Singh, Cit, Dr Date Of Hearing 10/07/2025 Date Of Pronouncement 06/08/2025 Order

Section 143(3)Section 144Section 147

order dated 30/03/2022, the Assessee preferred an Appeal before the Ld. CIT(A). Since, there was a delay of 171 days in filing the first Appeal, the Ld. CIT(A) vide order dated 10/04/2024 , dismissed the Appeal filed by the Assessee on delay in latches. Aggrieved by the order ... Assessee preferred the present Appeal. 3. The Ld. Counsel for the Assessee vehemently submitted that the Ld. CIT(A) has dismissed the first Appeal though there was sufficient cause the condone the delay, therefore, sought for allowing the present Appeal of the Assessee. 4. Per contra, the Ld. Departmental Representative

The Shree Daivadnya Urban Cooperative Credit Society Limited, Mapusa vs. Income Tax Officer, Panaji

The appeal is allowed for statistical purposes

ITA 85/PAN/2025[2017-18]Status: DisposedITAT Panaji05 Aug 2025AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2017-18 The Shree Daivadnya Urban Co-Op. Credit Society, Ltd. Office No. 211, 2Nd Flr., Cosmos Centre, Mapusa, Goa-403507 Pan:Aabat3738J . . . . . . . Appellant

For Appellant: None [‘Ld. AR’]For Respondent: Ms Rijjula Uniyal [‘Ld. DR’]

Section 139Section 142(1)Section 144Section 24Section 25Section 250Section 69A

section 250(6) of the Act. Any order to be regular & legal, it must comply with former threefold dictates. 8. An order passed in first appeal without adhering to former threefold stipulations de-facto, in our considered view sufferers from compliance of s/s (6) of section

Ayush Pavankumar Agrawal, Ahmedabad vs. The ITO, Ward-1(2)(1), Ahmedabad

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

ITA 583/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad05 Aug 2025AY 2018-19

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

For Appellant: Shri Sulabh Padshah, ARFor Respondent: Shri Hargovind Singh, Sr.DR

Section 133(6)Section 143(2)Section 143(3)Section 250Section 253(5)

filing portal of the Income Tax Department. The affidavit further states that the assessee became aware of the dismissal of the first appeal only in March 2025 during routine checking by his tax consultant, whereafter he took immediate steps to obtain a copy of the appellate order and filed

Victoria Educational Trust, Chennai vs. ITO, Exemption Ward-3, Chennai

The appeal of the assessee is allowed

ITA 946/CHNY/2025[2022-23]Status: DisposedITAT Chennai05 Aug 2025AY 2022-23

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:946/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2022-23 Victoria Educational Trust, Ito, 62, 6Th Street, Vs. Exemptions Ward 3, S.R.P.Colony, Chennai. Peravallur, Chennai – 600 082. [Pan:Aabtv-0115-A] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate प्रत्यथी की ओर से/Respondent By : Shri. Kumar Chandan, J.C.I.T.

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Kumar Chandan, J.C.I.T

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

condonation of delay in filing the audit report in Form No. 10B for the reasons stated thereon. 11. The assessee in the pending first appeal against the intimation order dated had assailed the adjustment of disallowance of entire claim of tax exemption in terms of Section ... adjustments permissible in terms of Section 143(1) of the Act. :-5-: ITA. No:946/Chny/2025 12. However, the said submissions in the pending first appeal were rejected by the FAA vide the appellate order dated 25.03.2025, wherein the FAA had held as follows: "12.1. Ground

Telkar Sreenivasarao Sathyanarayana Rao, Mandya vs. The Deputy Commissioner of Income Tax, Mysore

In the result, the appeal filed by the assessee stands dismissed as infructuous

ITA 118/BANG/2025[2017-18]Status: DisposedITAT Bangalore05 Aug 2025AY 2017-18

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmedassessment Years: 2017-18

For Appellant: Shri H Shankare Gowda, CAFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department

Section 147Section 24Section 250Section 263

borrowed capital u/s 24(b) of the Act. Page 2 of 3 3. The assessee being aggrieved, challenged the said addition/disallowance by filing first appeal before the Ld. Commissioner, who vide impugned order confirmed the aforesaid addition/disallowance by passing ex-parte order due to non- persecution by the assessee

Azad Coach Builders Private Limtied, Bangalore vs. Income Tax Officer, Ward-1(1)(2), Bangalore

In the result, the appeal filed by the assessee stands allowed

ITA 1978/BANG/2024[2012-13]Status: DisposedITAT Bangalore05 Aug 2025AY 2012-13

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmedassessment Years: 2012-13

For Appellant: Shri Ravishankar S.V, AdvocateFor Respondent: Shri Balusamy N, JCIT (DR)

Section 143(3)Section 250Section 269SSection 271Section 271D

271D of the Act for violation of sec. 269SS of the Act. 4. The assessee being aggrieved challenged the said penalty by filing first appeal before the Ld. Commissioner but could not get any relief, as the Ld. Commissioner vide impugned order affirmed the penalty by dismissing appeal filed

Sh. Ajay Kumar, Roorkee vs. CIT(A), 2-, Roorkee

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

ITA 182/DDN/2024[2016-17]Status: DisposedITAT Dehradun04 Aug 2025AY 2016-17

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

condone the inordinate delay in filing the Appeal before the Ld. CIT(A), therefore, submitted that the Ld. Ld. CIT(A) rightly dismissed the first appeal which requires no interference at the hands of the Tribunal, therefore, sought for dismissal of the present Appeal. 5. We have heard the Department ... delay of 65 days. However, the Assessee has not filed the application for condonation of delay, which led the Ld. CIT(A) in dismissing first appeal of the Assessee on delay in latches. 3 Sh. Ajay Kumar Vs. CIT(A) 6. Considering the above facts and circumstances of the case

Prahlad Das Goyal, Bhopal vs. DCIT - 1(1) Bhopal, Bhopal

Appeal is partly allowed

ITA 5/IND/2025[2016-17]Status: DisposedITAT Indore04 Aug 2025AY 2016-17

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2016-17 Prahlad Das Goyal, Dcit/Acit 1(1) 18, Shyamla Hills, Bhopal बनाम/ Bhopal Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Abbpg3494L Assessee By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 31.07.2025 Date Of Pronouncement 04.08.2025

Section 143(2)Section 143(3)Section 194Section 40

Date of Hearing 31.07.2025 Date of Pronouncement 04.08.2025 आदेश/ O R D E R Per B.M. Biyani, A.M.: Feeling aggrieved by order of first appeal dated 16.12.2024 passed by learned Commissioner of Income-Tax (Appeals)-Addl/JCIT(A)-10, Mumbai [“CIT(A)”] which in turn arises out of assessment-order dated ... made by assessee against purchase of land without making TDS u/s 194-IA. Aggrieved, the assessee carried matter in first-appeal whereupon the CIT(A) deleted disallowance relatable to the payment of Rs. 20,00,000/- accepting assessee’s argument that the said payment was made in May, 2013 before

Prince Tygai, Mohali vs. Income Tax Officer, Ward 6(4), Chandigarh

The appeal stand partly allowed

ITA 968/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh04 Aug 2025AY 2017-18

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.968/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2017-18) Shri Prince Tyagi Ito # 87 Ward No 1, Near Petrol Pump Ward-6(4) बनाम/ Vs. Mandi Kharar Sas Nagar, Mohali 140301 Chandigarh 160062 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Angpt-5979-E (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ" की ओर से/ Appellant By : Sh. Rahul Bhanot( Advocate) & Shri Puneet Singla (Advocate) – Ld. Ars ""थ" की ओर से / Respondent By : Dr. Ranjit Kaur (Addl.Cit) – Ld. Sr.Dr सुनवाईकीतारीख/Date Of Hearing : 23-07-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-08-2025 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 05-06-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] On Best Judgement Basis U/S 144 Of The Act On 19-12-2019. The Registry Has Noted Delay Of 40 Days In The Appeal

For Appellant: Sh. Rahul Bhanot( Advocate) and Shri PuneetFor Respondent: Dr. Ranjit Kaur (Addl.CIT) – Ld. Sr.DR

Section 144

representation from the assessee. The deposits were made in Bank of Baroda Account No.50530400000068 held in the name of M/s Surkum Enterprises. During first appeal, the assessee contended that it was engaged in selling recharge coupons of idea cellular Ltd. and working as an agent for the company on commission

Ritu Bangia, Ludhiana vs. Income Tax Officer Ward 7(1), Ludhiana

The appeal stand allowed for statistical purposes

ITA 1212/CHANDI/2024[2017-2018]Status: DisposedITAT Chandigarh04 Aug 2025AY 2017-2018

Bench: us. The only prayer of Ld. AR is admission of appeal and adjudication on merits. The Ld. CIT-DR has opposed the same.

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR

Section 144Section 68

under a bona fide belief that earlier counsel would take care of all Income Tax compliances. Due to these facts, delay happened in the first appeal. Upon perusal of these reasons, we find that the assessee had reasonable cause for not filing the appeal within time. Moreover, substantial period fall

DCIT, Central Circle-1, Ludhiana vs. M/S Ritish Agro Private Limited, Ludhiana

Appeal stand dismissed

ITA 638/CHANDI/2022[2019-20]Status: DisposedITAT Chandigarh04 Aug 2025AY 2019-20

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am Physical Hearing 1. आयकरअपीलसं./ Ita No. 633/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2019-20) M/S Ritish Agro Private Ltd. Dcit-Central Circle-1 बनाम/ Vs. Malerkotla Road, Rasulra Ludhiana Khanna – 141 401 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccr-7743-J (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपीलसं./ Ita No.638/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2019-20) Dcit-Central Circle-1 M/S Ritish Agro Private Ltd. बनाम/ Vs. Ludhiana Malerkotla Road, Rasulra Khanna – 141 401 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccr-7743-J (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashwani Kumar (Ca) & Ms. Muskan Garg (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Ms. Tarundeep Kaur (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 24-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-08-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Cross-Appeals Arises Out Of The Order Of Learned Commissioner Of Income Tax (Appeals)-5, Ludhiana Dated 26-07-2022

For Appellant: Shri Ashwani Kumar (CA) & MsFor Respondent: Ms. Tarundeep Kaur (CIT) – Ld. DR

Section 143(3)Section 145(3)Section 250(6)Section 36(1)(iii)Section 68

Rs.5500/- per Quintals and accordingly, addition of Rs.2779.48 Lacs was considered as unaccounted sales of the assessee and added to its income. 4.5 During first appeal, the assessee assailed estimation of yield on the basis of USA study. It was also stated there could never be 100% yield ... onus of proving these purchases, the same were added u/s 68 r.w.s. 69C of the Act to the income of the assessee. 7.2 During first appeal, it was contended by the assessee that nothing was brought on record to prove that cash was received back from these parties

M/S Ritish Agro Private Limited, Khanna vs. DCIT, Central Circle-1, Ludhiana

Appeal stand dismissed

ITA 633/CHANDI/2022[2019-20]Status: DisposedITAT Chandigarh04 Aug 2025AY 2019-20

For Appellant: Shri Ashwani Kumar (CA) & MsFor Respondent: Ms. Tarundeep Kaur (CIT) – Ld. DR

Section 143(3)Section 145(3)Section 250(6)Section 36(1)(iii)Section 68

Jaikusuma Balakrishna Shetty, Bangalore vs. Income Tax Officer, Ward-1(2)(2), Bangalore

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

ITA 1096/BANG/2025[2016-17]Status: DisposedITAT Bangalore04 Aug 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmedassessment Year : 2016-17

For Appellant: Ms. Sunaina Bhatia, Ld.CAFor Respondent: Sri Balasamy N – Ld.JCIT

Section 143(3)Section 154Section 234Section 250

merits of the case, we observe that before the Ld. 6. Commissioner also, there was a delay of 49 days in fling the first appeal, on which assessee has claimed that assessee instead of challenging the assessment order dated 30.12.2018 by filling 1st appeal, on being advised by the erstwhile ... however no order on such application, has been passed by the AO. Therefore on being further advised, the assessee preferred first appeal before the d. Commissioner, against the assessment order dated 30.12.2018 under section 143(3) of the Act. Smt Jaikusuma Balakrishna Shetty Page 4 of 5 7. We observe

Sidharth Cooperative Credit and Thrift Society Limited, Durg vs. Income Tax Officer, Ward-2(1), Bhilai, Durg

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

ITA 361/RPR/2023[2018-19]Status: HeardITAT Raipur01 Aug 2025AY 2018-19

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.361/Rpr/2023 "नधा"रण वष" /Assessment Year : 2018-19 Sidharth Co-Operative Credit & Thrift Society Limited. Nayapara Titrudhi, Durg-490 020 (C.G.) Pan: Aagas2471Q .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-2(1), Bhilai (C.G.) ……""यथ" / Respondent

For Appellant: Shri Yogesh Sethia, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 246ASection 250Section 260A

through the records and documents filed. 11. Indisputably, after the return was filed, the deduction claimed by the appellant was denied on 07.06.2019. Consequently, first appeal was filed under Section 246A, which was dismissed on 19.04.2022. The statute provides for rectification i.e. a review, in case where certain facts have ... proper to avail such remedy but did not succeed and eventually the rectification prayer was subsequently dismissed, thereby upholding the original order of first appeal on 19.4.2022. Against such rejection of the rectification application process of first appeal and second appeal was availed which were ultimately decided on 27.10.2023 which

Assistant Commissioner of Income Tax, Dehradun vs. Western Geco International Limited, Haryana

The Appeal of the Revenue is dismissed

ITA 141/DDN/2024[2022-23]Status: DisposedITAT Dehradun31 Jul 2025AY 2022-23

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwali.T.A. No. 141/Del/2024 (A.Y 2021-22)

Section 143(3)Section 44BSection 44DSection 9(1)(vii)

committed no error in following the order of the Special Bench in Assessee’s own case for Assessment Year 2011-12 and allowing the first appeal of the Assessee. Accordingly, finding no merits in the Grounds of appeal of the Revenue, the Appeal of the Revenue is dismissed. Order pronounced

The Muthada Khurd Co Operative Agri Multipurpose Society Limited, Jalandhar vs. Income Tax Officer Ward-1, Phagwara

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

ITA 481/ASR/2024[2019-2020]Status: DisposedITAT Amritsar31 Jul 2025AY 2019-2020

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

For Appellant: None (Adjournment application)

Section 139Section 143(1)Section 143(1)(a)Section 154Section 250Section 80ASection 80P

such considering all aspects of the matter , since it is clearly not ascertainable neither from the rectification order u/s 154 nor from the first appeal order ,the actual reasons for disallowance of claim u/s 80P of the Act , in the instant case , we set aside the matter back

Srithik Ispat Private Limited, Goa vs. The Assistant Commissioner of Income Tax Circle 2(1) Panaji, Goa, Panaji

The appeal is allowed for statistical purposes

ITA 48/PAN/2025[2016-17]Status: DisposedITAT Panaji31 Jul 2025AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year: 2016-17 Srithik Ispat Pvt. Ltd. Plot No. 3, Sanguem Industrial Estate, Sanguem, Goa-403704 Pan : Aaics1765P . . . . . . . Appellant V/S Asstt. Commissioner Of Income Tax, Circle-2(1), Panaji, Goa . . . . . . . Respondent Appearances Assessee By: Mrs Girija Agrawal [‘Ld. Ar’] Revenue By: Ms Rijjula Uniyal [‘Ld. Dr’] Date Of Conclusive Hearing: 30/07/2025 Date Of Pronouncement : 31/07/2025 Order Per G. D. Padmahshali; This Assessee’S Appeal Is Filed U/S 253(1) Of The Income-Tax Act, 1961 [‘The Act’] Challenges Din & Order No 1068425181(1) Dt. 06/09/2024 Passed By National Faceless Appeal Centre, Delhi [‘Ld. Cit(A)/Nfac’] U/S 250 Of The Act Which Originated From Order Of Assessment Passed U/S 144 Of The Act By Asstt. Commissioner Of Income Tax, Circle-2(1), Panaji, Goa. [‘Ld. Ao’].

For Appellant: Mrs Girija Agrawal [‘Ld. AR’]For Respondent: Ms Rijjula Uniyal [‘Ld. DR’]

Section 143(2)Section 144Section 250Section 251Section 251(1)(a)Section 253(1)Section 40Section 68

order to be regular & legal, it must comply with former threefold dictates. 8. An order passed in first appeal without adhering to former threefold stipulations de-facto, in our considered view sufferers from compliance of s/s (6) of section 250 of the Act, therefore in limine deserves