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“appeal before the tribunal”

AppealsSection 253Section 25316,033 judgments

The decision most relied on for appeal before the tribunal is CIT v. Multiplan India Ltd. (38 ITD 320), cited in 2,267 judgments on BharatTax.

Leading authorities on appeal before the tribunal

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

Estate of Late Tukojirao Holkar v. CWT
223 ITR 480 · 1997 · High Court
2,040
citing judgments

A court or tribunal is not bound to answer a reference or adjudicate an appeal on its merits if the party at whose instance the proceeding is made fails to appear at the hearing or take necessary steps for its proper conduct.

CIT v. Pruthvi Brokers & Shareholders
349 ITR 336 · 2012 · High Court
956
citing judgments

Appellate authorities can entertain fresh claims or revised computations of income made by an assessee, even if these were not submitted through a revised return of income.

National Thermal Power Co. Ltd. v. CIT
389 ITR 326 · 2016 · High Court
241
citing judgments

An appellate authority can admit and adjudicate additional grounds of appeal if they are legal in nature or go to the root of the matter, even if not raised before lower authorities or filed belatedly.

Commissioner of Income Tax Madras v. Chenniyappa Mudiliar
1 SCC 591 · 1985 · Reported
225
citing judgments

The appellate tribunal must render a proper decision on both facts and law, disposing of an appeal on its merits rather than dismissing it solely due to the appellant's absence. This obligation is derived from Section 33(4) of the Income Tax Act, 1922, and reflects principles of natural justice.

Otters Club v. DIT
392 ITR 244 · 2017 · High Court
202
citing judgments

The Bombay High Court did not approve an order being passed by the Tribunal beyond a period of 90 days.

CIT v. Bharat General Reinsurance Co Ltd.
81 ITR 303 · 1971 · High Court
202
citing judgments

Income received by an assessee for services rendered to an Indian company may not be taxable, particularly when the Revenue does not contest its non-taxability. This principle aligns with CBDT Circular No. 14 of 1955, which has been approved by the Supreme Court.

Shivsagar Veg Restaurant v. ACIT
317 ITR 433 · 2009 · High Court
202
citing judgments

Orders that are inordinately delayed are liable to be recalled and heard afresh, and the Appellate Tribunal President should frame guidelines for timely disposal of appeals.

Judgments citing appeal before the tribunal

Dinesh Kumar, Delhi vs. DCIT, Central Circel-07, Delhi

In the result appeal of the assessee is allowed

ITA 3312/DEL/2025[2009-10]Status: DisposedITAT Delhi26 Nov 2025AY 2009-10

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos.3311 To 3313/Del/2025 (Assessment Years 2008-09 To 2010-11) Dinesh Kumar, Dcit, 407, Nilgiri Apartments, Central Circle-07, Alaknanda, New Delhi-110019. Vs. New Delhi. Pan-Aiopg3637K (Appellant) (Respondent) Assessee By Shri Nirbhay Mehta, Adv. Department By Shri Mahesh Kumar, Cit- Dr Date Of Hearing 15.09.2025 Date Of Pronouncement 26.11.2025 O R D E R Per Manish Agarwal, Am: All These Three Appeals Are Filed By The Assessee Against The Three Separate Orders Passed By The Ld. Commissioner Of Income Tax (Appeals)-24, New Delhi [Cit(A) In Short] All Are Dated 20.03.2025 For Assessment Years 2008-09, 2009-10 & 2010-11 Respectively.

Section 132Section 143(3)Section 153ASection 254Section 263Section 68

Revenue by Ld. PCIT vide its order dated 30.03.2018 passed u/s 263 of the Act. Against the said order, the assessee filed appeal before the Tribunal who dismissed the appeal of the assessee, thus, thereafter, the AO proceeded to pass the order incompliance to the directions given by Ld. PCIT ... Against the said order, the assessee preferred the appeal before the Ld. CIT(A) who dismissed the appeal, therefore, the assessee in his appeal before the Tribunal by taking the following rounds of appeal: “1. That on the facts and circumstances of the case and in law, the appellate order

Dinesh Kumar, Delhi vs. DCIT, Central Circle-07, Delhi

In the result appeal of the assessee is allowed

ITA 3311/DEL/2025[2008-09]Status: DisposedITAT Delhi26 Nov 2025AY 2008-09

Bench: Shri Anubhav Sharma & Shri Manish Agarwalita Nos.3311 To 3313/Del/2025 (Assessment Years 2008-09 To 2010-11) Dinesh Kumar, Dcit, 407, Nilgiri Apartments, Central Circle-07, Alaknanda, New Delhi-110019. Vs. New Delhi. Pan-Aiopg3637K (Appellant) (Respondent) Assessee By Shri Nirbhay Mehta, Adv. Department By Shri Mahesh Kumar, Cit- Dr Date Of Hearing 15.09.2025 Date Of Pronouncement 26.11.2025 O R D E R Per Manish Agarwal, Am: All These Three Appeals Are Filed By The Assessee Against The Three Separate Orders Passed By The Ld. Commissioner Of Income Tax (Appeals)-24, New Delhi [Cit(A) In Short] All Are Dated 20.03.2025 For Assessment Years 2008-09, 2009-10 & 2010-11 Respectively.

Section 132Section 143(3)Section 153ASection 254Section 263Section 68

Revenue by Ld. PCIT vide its order dated 30.03.2018 passed u/s 263 of the Act. Against the said order, the assessee filed appeal before the Tribunal who dismissed the appeal of the assessee, thus, thereafter, the AO proceeded to pass the order incompliance to the directions given by Ld. PCIT ... Against the said order, the assessee preferred the appeal before the Ld. CIT(A) who dismissed the appeal, therefore, the assessee in his appeal before the Tribunal by taking the following rounds of appeal: “1. That on the facts and circumstances of the case and in law, the appellate order

Ashok Kumar Jain, Delhi vs. Pr, CIT 20, New Delhi

ITA 2641/DEL/2025[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2018-19 Ashok Kumar Jain, Vs. Pr. Cit-20, C/O Kapil Goel, Advocate, New Delhi. F-26/124, Sector-7, Rohini, Delhi – 110 085. Pan: Aakpj1872B

For Appellant: Dr. Kapil Goel, AdvocateFor Respondent: Ms Pooja Swaroop, CIT-DR
Section 147Section 148ASection 151Section 263Section 69C

also held the reassessment to be bad in law on jurisdictional ground. Against the order of the AAC the Revenue went in appeal before the Tribunal and specifically raised the plea that the question of jurisdiction to reopen the assessment having been expressly given up by the assessee

Asian Resources Limited, Delhi vs. Income Tax Officer Ward 3(3), Income Tax Officer

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

ITA 2525/DEL/2025[2010-11]Status: DisposedITAT Delhi26 Nov 2025AY 2010-11

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalasian Resources Limited Vs Income Tax Officer M-116A, Iind Floor, Ward 3(3) Connaught Place, New Delhi Room No. 392, Central Pan: Aahca0844Q Revenue Building, I. P. Estate, New Delhi Appellant Respondent Assessee By Sh. Mukesh Mittal, Ca Revenue By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 19/11/2025 Date Of Pronouncement 26/11/2025 Order

diseases and the Assessee could not check the e-mail, which resulted 2 Asian Resources Ltd. Vs. ITO in filing the Appeal before the Tribunal belatedly. Thus, sought for condoning the delay in filing the present Appeal. 3. Per contra, the Ld. Department's Representative submitted that, there ... have heard both the parties and perused the material available on record on the issue of delay in filing the present Appeal before the Tribunal. The Assessee in the Application for condonation of delay contended that the business of the Assessee was closedown since past so many years

Alstom Transport Sa, Karnataka vs. DCIT, Int. Taxation Circle 1(1)(1), Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1715/DEL/2025[2022-23]Status: DisposedITAT Delhi26 Nov 2025AY 2022-23

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

equipment and spare parts were claimed as not taxable in India by the assessee. It was subsequently by way of additional ground of appeal before the Tribunal that the assessee has claimed that receipts in respect offshore designing and other services are not taxable in India. 12. The assessee ... Officer with regard to the status of assessee having PE in India. The assessee carried the assessment order for AY 2021-22 in appeal before the Tribunal in ITA No. 3858/Del/2023. The Tribunal vide order dated 30.05.2024 has restored the issue back to the AO for denovo assessment in accordance

Alstom Transport Sa, Karnataka vs. DCIT, Int. Taxation Circle 1(1)(1), Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1714/DEL/2025[2015-16]Status: DisposedITAT Delhi26 Nov 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

equipment and spare parts were claimed as not taxable in India by the assessee. It was subsequently by way of additional ground of appeal before the Tribunal that the assessee has claimed that receipts in respect offshore designing and other services are not taxable in India. 12. The assessee ... Officer with regard to the status of assessee having PE in India. The assessee carried the assessment order for AY 2021-22 in appeal before the Tribunal in ITA No. 3858/Del/2023. The Tribunal vide order dated 30.05.2024 has restored the issue back to the AO for denovo assessment in accordance

Alstom Transport Sa, Bangalore vs. DCIT Intl. Taxation Circle 1(1)(1), New Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1713/DEL/2025[2014-15]Status: DisposedITAT Delhi26 Nov 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

equipment and spare parts were claimed as not taxable in India by the assessee. It was subsequently by way of additional ground of appeal before the Tribunal that the assessee has claimed that receipts in respect offshore designing and other services are not taxable in India. 12. The assessee ... Officer with regard to the status of assessee having PE in India. The assessee carried the assessment order for AY 2021-22 in appeal before the Tribunal in ITA No. 3858/Del/2023. The Tribunal vide order dated 30.05.2024 has restored the issue back to the AO for denovo assessment in accordance

Alstom Transport Sa, Bangalore vs. DCIT Intl. Taxation Circle 1(1)(1), New Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1712/DEL/2025[2013-14]Status: DisposedITAT Delhi26 Nov 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

equipment and spare parts were claimed as not taxable in India by the assessee. It was subsequently by way of additional ground of appeal before the Tribunal that the assessee has claimed that receipts in respect offshore designing and other services are not taxable in India. 12. The assessee ... Officer with regard to the status of assessee having PE in India. The assessee carried the assessment order for AY 2021-22 in appeal before the Tribunal in ITA No. 3858/Del/2023. The Tribunal vide order dated 30.05.2024 has restored the issue back to the AO for denovo assessment in accordance

Alstom Transport Sa, Karnataka vs. DCIT International Taxation, Circle 1(1)(1), New Delhi

In the result, impugned assessment order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 1711/DEL/2025[2011-12]Status: DisposedITAT Delhi26 Nov 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.1711 To 1715/िद"ी/2025(िन.व. 2011-12, 2013-14 To 2015-16 और 2022-23)

For Appellant: Shri Deepak Chopra & Ms. Priyan TandonFor Respondent: Shri Nikhil Kumar Govila, CIT(DR)

equipment and spare parts were claimed as not taxable in India by the assessee. It was subsequently by way of additional ground of appeal before the Tribunal that the assessee has claimed that receipts in respect offshore designing and other services are not taxable in India. 12. The assessee ... Officer with regard to the status of assessee having PE in India. The assessee carried the assessment order for AY 2021-22 in appeal before the Tribunal in ITA No. 3858/Del/2023. The Tribunal vide order dated 30.05.2024 has restored the issue back to the AO for denovo assessment in accordance

Raj Kumar Daga HUF, Delhi vs. ACIT Circle 30(1), Delhi

In the result, appeal of the assessee is allowed

ITA 709/DEL/2024[2014-2015]Status: DisposedITAT Delhi26 Nov 2025AY 2014-2015

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 234Section 234ASection 250

vide order dated 22.12.2023, dismissed the appeal of the assessee. 6. Aggrieved by the order of Ld.CIT(A), assessee is in appeal before the Tribunal by taking following grounds of appeal:- 1. “That the learned Commissioner of Income-Tax (A) is wrong is determining the total income at Rs.80

Raj Kumar Daga HUF, Delhi vs. ACIT Circle 30(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 699/DEL/2024[2013-2014]Status: DisposedITAT Delhi26 Nov 2025AY 2013-2014

Bench: Shri Sudhir Kumar & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 234Section 234ASection 250

vide order dated 22.12.2023, dismissed the appeal of the assessee. 6. Aggrieved by the order of Ld.CIT(A), assessee is in appeal before the Tribunal by taking following grounds of appeal:- 1. “That the learned Commissioner of Income-Tax (A) is wrong is determining the total income at Rs.80

Shri Vardhaman Sthanakwasi Shraman, Durg vs. ITO-1(1), Bhilai

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

ITA 662/RPR/2025[2017-18]Status: HeardITAT Raipur25 Nov 2025AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.662/Rpr/2025 "नधा"रण वष" /Assessment Year : 2017-18 Shri Vardhman Sthanakwasi Shraman Sanghiya Sharavk Sangh Trust Pravin Kumar Jain, Bandha Talab Ganjpara, Durg-491 001 (C.G.) Pan: Aalts4890F .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(1), Bhilai (C.G.)

For Appellant: Shri Sangeet Bakliwal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(3)Section 250Section 270ASection 44A

submitted that when order u/s.263 of the Act was passed, they were aggrieved, however, due to COVID Pandemic period, they could not file appeal before the Tribunal against the said order. It was submitted that during the consequential assessment proceedings, they had prayed before the A.O to consider the documents

Amrit Lal Khairwar, Champa, Chhattisgarh vs. Income-Tax Officer Janjgir-Champa, Champa

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

ITA 503/RPR/2025[2014-15]Status: DisposedITAT Raipur25 Nov 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.503/Rpr/2025 िनधा"रण वष" /Assessment Year: 2014-15 Amrit Lal Khairwar, Indira Nagar, Behind Govt, City Hospital, Janjgir, Khadipadi Para, Janjgir, Champa, 495668, Chhattisgarh. Pan: Dudpk4562H .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Mr. S.R. Rao, AdvocateFor Respondent: Dr. Priyanka Patel, Sr.DR

Officer, Janjgir-Champa of the parties, it is crystal clear that the said ordinate delay of 238 days regarding filing of the appeal before the Tribunal is due to the circumstances and lack of timely professional assistance to the assessee. Nothing has been brought on record to suggest any malafide

Rani Devi, Patna vs. Income Tax Officer, Patna

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

ITA 308/PAT/2025[2017-18]Status: DisposedITAT Patna25 Nov 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 145(3)Section 250Section 44ASection 69ASection 80C

Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2017-18 dated 04.09.2024. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. For that the impugned order is bad in law as well as on facts and requires ... Appeals), she approached the ld. A.R. to prefer an appeal, due to that there was a delay of 212 days in filing the appeal before the Tribunal. Therefore, she pleaded to condone the delay. 4. Considering the facts and circumstances of the case, we are of the view that

Anil Hanumant Choudhari, Pune vs. Income Tax Officer Ward 8(3) Pune, Pune

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

ITA 406/PUN/2025[2020-21]Status: DisposedITAT Pune25 Nov 2025AY 2020-21

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri B.R. BarveFor Respondent: Shri Ramnath P. Murkunde
Section 143(2)Section 144Section 251Section 54F

appellant is deemed to be invalid/infructuous as well, and the grounds raised by the appellant are dismissed.” 5. Dissatisfied, the assessee is in appeal before the Tribunal and all the grounds of appeal relate thereto. 6. The Ld. AR at the outset submitted that the Ld. AO has completed

Khandesh Maratha Mandal, Pune vs. CIT (Exemption), Pune

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

ITA 1302/PUN/2025[-]Status: DisposedITAT Pune25 Nov 2025

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Abhilash HiranFor Respondent: Shri Amol Khairnar
Section 80GSection 80G(5)Section 80G(5)(vi)

above, the application dated 07/10/2024 in form 10AB filed by the assessee is hereby rejected.” 4. Aggrieved, the assessee is in appeal before the Tribunal and all the grounds of appeal relate thereto. 5. The Ld. AR submitted that the assessee has filed two applications with

Satgramr. Colliery Employees Cooperative Credit Society Limited, Asansol vs. Assistant Commissioner of Income Tax, Circle-1, Asansol

In the result, the appeal of the assessee is allowed

ITA 1920/KOL/2025[2019-2020]Status: DisposedITAT Kolkata25 Nov 2025AY 2019-2020

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1920/Kol/2025 Assessment Year: 2019-20 Satgram R Collery Employees Cooperative Credit Society Ltd……....Appellant Satgram Project, P.O Debichand Nagar, Block-Jamuria-1, Asansol, W.B. 713332. [Pan: Aajas8427K] Vs. Acit, Circle-1, Asansol……..……………....…..………………….…..... Respondent Appearances By: Shri Abhijit Banerjee, Advocate, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborty, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 24, 2025 Date Of Pronouncing The Order : November 25, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre (Hereinafter Referred To As “Ld. Cit(A)”) Dated 03.02.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. At The Time Of Hearing Of The Matter, The Learned Representative Submitted That There Was A Delay Of 115 Days In Filing The Appeal. In This Connection, The Assessee Filed An Affidavit Explaining The Reasons For The Delay. After Considering The Submissions Of The Assessee & Examining The Contents Of The Affidavit, We Are Satisfied That The Reasons For The Delay Are Bona Fide & Deserve To Be Condoned.

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

Aggrieved, the assessee filed an appeal before the CIT(A), who sustained the disallowance. 5. The assessee is now in further appeal before the Tribunal. The assessee contends that the intimation under section 143(1) dated 29.09.2020 was passed before the amendment to section

Gurkripa Enterprises, Kolkata vs. ITO, Ward 40(3), Kolkata

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

ITA 1594/KOL/2025[2017-18]Status: DisposedITAT Kolkata25 Nov 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 119Section 250Section 30Section 43

Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2017-18 dated 15.05.2025. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: 1.The impugned order was passed by the Learned CIT (Appeals) without affording the assessee its right to have proper ... Appeals), he approached the ld. A.R. to prefer an appeal, due to which there is a delay of 1850 days in filing the appeal before the Tribunal. Therefore, he pleaded to condone the delay. 4. Considering the facts and circumstances of the case, we are of the view that

M.A. Financial Services Pvt. Ltd., Kolkata vs. ITO, Ward 4(1), Kolkata

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

ITA 1273/KOL/2025[2018-2019]Status: DisposedITAT Kolkata25 Nov 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 147Section 148Section 148ASection 151ASection 250

Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2018-19 dated 15.05.2025. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1) That on the facts and in the circumstances of the case, the action ... result, the appeal of the assessee is dismissed.” 5. Aggrieved with the order of the Ld. CIT(A), the assessee has filed the appeal before the Tribunal. 6. Rival contentions were heard and the submissions made have been examined. At the outset, the ld. A.R. of the assessee argued that

Chenniappa Gounder Deivasigamani, Kangayam vs. Ward I(4) / Tirupur, Tirupur

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

ITA 2380/CHNY/2025[2017-18]Status: DisposedITAT Chennai25 Nov 2025AY 2017-18

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.: 2380/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Shri Chenniappa Gounder The Income Tax Officer, Deivasigamani, Vs. Ward 1(4), 565/4-A, Tirupur Sivamathy Modern Rice Mill, Agasthilingampalayam Road, Tiruppur – 638 701. Pan: Aenpd 8814L (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Harinandha Kumar, Ca (Through Virtual Mode) ""यथ" क" ओर से/Respondent By : Ms. T. Mythili, Jcit सुनवाई क" तारीख/Date Of Hearing : 25.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 25.11.2025

For Appellant: Shri Harinandha Kumar, CAFor Respondent: Ms. T. Mythili, JCIT
Section 147Section 148Section 250Section 69A

made by the AO was confirmed by the FAA. :- 4 -: 5. Aggrieved by the order of the FAA, assessee has filed the present appeal before the Tribunal. The Ld.AR reiterated the submissions made before the AO and the FAA. 6. The Ld.DR strongly supported the orders of the Income