“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

Gsma Ltd, Usa vs. ACIT Circle Intl Taxation 1(3)(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 2446/DEL/2024[2017-18]Status: DisposedITAT Delhi04 Nov 2025AY 2017-18

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.2446/िद"ी/2024(िन.व. 2017-18) Gsma Ltd., 1000 Abernathy Road, Suite 450, Atalanta, Untied State Of America ...... अपीलाथ"/Appellant Pan: Aaecg-1610-K बनाम Vs. Assistant Commissioner Of Income-Tax, International Taxation 1(3)(1), Civic Centre, ....."ितवादी/Respondent Minto Road, New Delhi 110002 अपीलाथ" "ारा/ Appellant By: Shri P.P Singh, Advocate "ितवादी"ारा/Respondent By: Shri M.S Nethrapal, Cit-Dr सुनवाई क" ितिथ/ Date Of Hearing : 06/08/2025 घोषणा क" ितिथ/ Date Of Pronouncement : 04/11/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 06.04.2021 Passed U/S. 143(3) R.W.S 144C(13) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’), For Assessment Year 2017-18. 2. The Registry Has Issued Defect Memo Stating That The Appeal Is Time Barred By 1076 Days. The Assessee Has Filed An Application Supported By An Affidavit Citing Reasons For Delay In Filing Of Appeal.

For Appellant: Shri P.P Singh, AdvocateFor Respondent: Shri M.S Nethrapal, CIT-DR

Section 143(3)Section 9(1)(vii)

made by the Revenue in AY 2013-14 and 2015-16 holding Administration Fee as royalty. The assessee carried the issue in appeal before the Tribunal in ITA No.1980/Del/2017 for AY 2013-14 and ITA No. 3035/Del/2019 for AY 2015-16. 4 The Tribunal vide common order dated 08.12.2023 deleted ... well as under Article 12(3) of India-US DTAA. The assessee carried the issue in appeal before the Tribunal in ITA No. 1980/Del/2017 and ITA No.3035/Del/2019 for the respective assessment years. The Co-ordinate Bench 6 vide order dated 08.12.2023, decided the issue in favour of the assessee, holding

M/S Coper Co. Operative Sugar Ltd, Tapi vs. ITO Ward-2, Bardoli

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

ITA 24/SRT/2025[2014-15]Status: DisposedITAT Surat03 Nov 2025AY 2014-15

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.24/Srt/2025 Assessment Year: (2014-15) (Hybrid Hearing) M/S Coper Co-Operative Sugar Ltd., Vs. Ito, At & Post - Dadariya, Tal – Valod, Dist – Ward – 2, Tapi - 394630 Bardoli "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaac5824F (Appellant) (Respondent) Appellant By Shri Akshay M. Modi, Ca Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 07/08/2025 Date Of Pronouncement 03/11/2025

Section 143(2)Section 250Section 250(6)

dismissed the appeal of the assessee. 5. Aggrieved by the order of CIT(A), the assessee filed appeal before the Tribunal. The learned Authorized Representative (ld. AR) of the assessee filed a ITA No.24/SRT/2025/AY.2014-15 M/s Coper Co-op. Sugar Ltd. small paper book containing copy of notices issued

Usman Vali Patel, Bharuch Gujarat vs. Ward 1(2), Income Tax Officer, Bharuch

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

ITA 183/SRT/2025[2011-12]Status: DisposedITAT Surat03 Nov 2025AY 2011-12

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.183/Srt/2025 Assessment Year: (2011-12) (Hybrid Hearing) Usman Vali Patel, Vs. Ito, A-14 Assd Park, Near Khwaja Ward – 1(2), Township, Bharuch - 392001 Bharuch "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aykpp8165B (Appellant) (Respondent) Appellant By Shri Krutarth Desai, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 11/09/2025 Date Of Pronouncement 03/11/2025

Section 143(2)Section 143(3)Section 147Section 148Section 250Section 253(3)Section 69A

provisions of section 253(3) of the Act. The assessee has filed an affidavit giving reasons for delay in filing the appeal of appeal before the Tribunal. In the affidavit, the assessee stated that he is not well educated to understand the e-proceedings or faceless assessment and appeal scheme ... Chartered Accountant has not communicated the assessee about fate of appeal due to which, the delay of 318 days has occurred in filing appeal before the Tribunal. We note that assessee was not negligent but due to lack of communication with the tax consultant, there was delay in filing

Bipin Motibhai Patel, Bharuch vs. Income Tax Officer Bharuch Ward 1(1), Bharuch

In the result, the appeal of the assessee is dismissed

ITA 182/SRT/2025[2008-09]Status: DisposedITAT Surat03 Nov 2025AY 2008-09

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.182/Srt/2025 (Assessment Year: 2008-09) (Hybrid Hearing) Bipin Motibhai Patel, Vs. The Ito, F-1, Patel Faliya, Dasan, At Po Ward – 1(1), Dasan, Bharuch - 392001 Bharuch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aqtpp8142R (Appellant) (Respondent) Appellant By None Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 06/08/2025 Date Of Pronouncement 03/11/2025

Section 139(1)Section 144Section 148Section 250Section 271(1)(c)

that the penalty imposed by the AO was confirmed by the CIT(A). Aggrieved by the order of CIT(A), the assessee filed appeal before the Tribunal. 5. No written submission was filed by the appellant nor anyone attended on behalf of the assessee. Therefore, no oral or written submission

Rajan Budhisagar Singh, Na vs. Arivs.ITO, Ward-4, Navsari

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

ITA 13/SRT/2025[2018-19]Status: DisposedITAT Surat03 Nov 2025AY 2018-19

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.13/Srt/2025 Assessment Year: (2018-19) (Hybrid Hearing) Rajan Budhisagar Singh The Income Tax Officer, बनाम/ 506, Priti Complex, Ward – 4, Navsari Vs. Shital Park Society, Opp. Jalkamal Society, Navsari – 396445, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahkps9432M (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रतीकीओरसे/Appellant By Shri Sujesh C. Suratwala, Ca राज"कीओरसे /Respondent By Shri Ajay Uke (Sr. Dr)With Shri Kevin Langaliya, C.A. सुनवाई की तारीख/Date Of Hearing 06/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 03/11/2025

Section 142(1)Section 143(3)Section 250Section 40ASection 40A(3)

assessee and passed the order u/s 250 of the Act on 26.12.2024. 5. Aggrieved by the order of CIT(A), assessee filed present appeal before the Tribunal. The learned Authorized Representative (ld. AR) of the assessee submitted that the assessee was engaged in the business of plying and hiring

Deputy Commissioner of Income Tax Circle 111, Surat vs. Mukesh Arjanbhai Maniya, Surat

In the result, appeal of revenue is dismissed

ITA 105/SRT/2025[2017-18]Status: DisposedITAT Surat03 Nov 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.105/Srt/2025 Assessment Year: 2017-18 (Hybrid Hearing) Deputy Commissioner Of Mukesh Arjanbhai Maniya बनाम/ Income Tax, Circle - 1(1)(1), C-303, Afil Tower, L.H. Road, Vs. Surat, Room No.108, 1St Varachha, Surat-395 006 Floor, Aayakar Bhawan, Majura Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Afepm 7227 A (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Sapnesh R Sheth, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 05/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 03/11/2025

Section 133ASection 139(1)Section 143(3)Section 148Section 250Section 250(2)Section 68

favour of the assessee and appeal of the assessee was, therefore, allowed. 7. Aggrieved by the order of CIT(A), revenue filed present appeal before the Tribunal. The Ld. Sr. DR for the revenue submitted that the decision of the Ld. ITA No.105/Srt/2025 A.Y 17-18 Mukesh A Maniya

Gau Jeev Parmarth Sewa Sanstha, Alwar vs. ITO(E), Ward-1, Jaipur

In the result, appeal filed by the assessee is allowed

ITA 1203/JPR/2025[2022-23]Status: DisposedITAT Jaipur03 Nov 2025AY 2022-23

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

For Appellant: Shri P.C. Parwal, FCAFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT

Section 11Section 12ASection 2Section 250

considered as income and tax imposed accordingly. After the rejection of application for registration u/s 12AB by CIT (Exemption), assessee has filed an appeal before the Tribunal. The 5 Gau Jeev Parmarth Sewa Sanstha, Alwar. ITAT has set aside the issue of registration under section 12AB vide order dated

Rajnee Dong, Siliguri vs. Income Tax Officier, Ward Three, Darjeeling

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

ITA 1065/KOL/2025[2014-15]Status: DisposedITAT Kolkata03 Nov 2025AY 2014-15

Bench: Shri Sonjoy Sarma, Jm & Shri Sanjay Awasthi, Am Rajnee Dong Income Tax Officer Grace Arjun Homes, Salabari, Ward Three, Darjeeling, Near Monestry Road, Darjiling-734101, Vs. Siliguri-734002, West Bengal West Bengal (Appellant) (Respondent) Pan No. Ajipd2993C Assessee By : Shri Siddharth Agarwal, Ar Revenue By : Ms. Monalisha Pal Mukherjee, Dr Date Of Hearing: 30.10.2025 Date Of Pronouncement : 03.11.2025

For Appellant: Shri Siddharth Agarwal, ARFor Respondent: Ms. Monalisha Pal Mukherjee, DR

Section 148

observing that the assessee failed to substantiate her claim or furnish supporting documents during appellate proceedings. 04. The assessee has now preferred an appeal before the Tribunal with a delay of 108 days in filing. Along with the appeal, the assessee filed a petition explaining the reasons for the delay

Pulak Samanta, Purba Bardhaman vs. ITO, Ward 2(3), Burdwan

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

ITA 1027/KOL/2025[2017-2018]Status: DisposedITAT Kolkata03 Nov 2025AY 2017-2018

Bench: Shri Sonjoy Sarma, Jm & Shri Sanjay Awasthi, Am Shri Pulak Samanta Ito, Ward 2(3), Burdwan S/O Sushil Samanta, Kharga Aaykar Bhawan Poorva, Karanda, P.S. Memari, Dist. Kachari Road, Court Compound, Vs. Purba Bardhaman, Pin-713149 Burdwan-713101, West Bengal West Bengal (Respondent) (Appellant) Pan No. Benps8092A Assessee By : Shri Suvo Chakroborthy, Ar Revenue By : Shri Monalisha Pal Mukherjee, Dr Date Of Hearing: 30.10.2025 Date Of Pronouncement : 03.11.2025

For Appellant: Shri Suvo Chakroborthy, ARFor Respondent: Shri Monalisha Pal Mukherjee, DR

Section 115BSection 68

sustained, holding that the assessee failed to substantiate the source of these credits with documentary evidence. 07. Aggrieved, the assessee is now in appeal before the Tribunal. There is a delay of 194 days in filing the appeal. The assessee filed a petition explaining the reasons for delay. After considering

Shreyans Overseas Pvt. Ltd., Kolkata vs. ITO, Ward - 8(2), Kolkata

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 2455/KOL/2024[2012-13]Status: DisposedITAT Kolkata03 Nov 2025AY 2012-13

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 201Section 250Section 263Section 40

passing of appellate order dismissing the appeal. The assessee was unaware of the appellate order. Thereafter, he approached the Counsel for filling the appeal before the Tribunal. Due to this there is delay in filing of the appeal. After perusing the same, we find force in the reasons mentioned therein ... instant appeals within statutory time limit. We, therefore, condone the delay and admit the appeals for adjudication. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: I. ITA No. 2454/KOL/2024, AY 2011-12: “1. That the Order passed

Shreyans Overseas Pvt. Ltd., Kolkata vs. ITO, Ward - 8(2), Kolkata

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 2454/KOL/2024[2011-12]Status: DisposedITAT Kolkata03 Nov 2025AY 2011-12

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 201Section 250Section 263Section 40

M/S. Excella Realtors Private Limited, Kolkata vs. I.T.O., Ward - 1(3), TDS, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2274/KOL/2024[2014-2015]Status: DisposedITAT Kolkata03 Nov 2025AY 2014-2015

Bench: Shri Manunatha G & Shri Sonjoy Sarmai.T.A. No.2274/Kol/2024 Assessment Year: 2014-15 M/S Excella Realtors Pvt. Ltd..........................................................……….…Appellant 2, Dharma Das Row, Rash Behari Avenue, W.B-700026. [Pan: Aacce1856B] Vs. Ito, Ward-1(3), Tds, Kolkata………………….…..….......……..…...…..…..Respondent Appearances By: Shri Jaydeep Chakraborty, Ar, Appeared On Behalf Of The Revenue. Shri Sallong Yaden, Addl. Cit-Dr, Appeared On Behalf Of The Assessee. Date Of Concluding The Hearing : September 18, 2025 Date Of Pronouncing The Order : November 03, 2025 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Kolkata [Hereinafter Referred To As “Cit(A)”] Dated 01.10.2024, Arising Out Of The Order Passed Under Section 200A(1) Of The Income-Tax Act, 1961 (“The Act”) For The Assessment Year 2014-15. 2. Brief Facts Of The Case Are That The Assessee, M/S Excella Relators Private Limited, Is Engaged In The Business Of Construction & Land Development. A Demand Notice Was Issued By The Tds-Cpc, Kolkata, Raising A Total Demand Of ₹4,59,653. After Giving Credit For Certain Adjustments Available In The Traces Portal, An Outstanding Demand Of ₹99,482 Towards Interest Under Section 201(1A) & ₹46,400 Towards Late Fee Under Section 234E Remained Payable.

Section 200A(1)Section 200A(1)(c)Section 201Section 234E

before the CIT(A), who, however, confirmed the action of the TDS Officer. 4. Being further aggrieved, the assessee has preferred the present appeal before the Tribunal. The primary grounds raised by the assessee are that the order of the CIT(A) is bad in law and on facts

Padma Pharmaceuticals, Jamkhandi vs. ACIT, Circle-1, Bijapur

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

ITA 141/BANG/2025[2017-18]Status: DisposedITAT Bangalore03 Nov 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Ashok Mudnur, CAFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department

Section 250(6)

event of illness of one partner, the other partners could have pursued the matter so as to avoid delay in filing the appeal before the Tribunal. 4. We have heard the rival contentions of both the parties and perused the materials on record. Considering the reasons stated in the condonation

Malan Mohan Khade, Mumbai vs. Jurisdiction Ward 41(4)(2), Mumbai

In the result the appeal filed by the assessee is

ITA 5610/MUM/2025[2018-19]Status: DisposedITAT Mumbai03 Nov 2025AY 2018-19

Bench: Shri Sandeep Gosain

Section 250Section 68

which occurred in filing the appeal and construing the expression" sufficient cause" liberally I am inclined to codone the delay in filing the appeal before the Tribunal. Therefore I condone the delay and admit the appeal to be heard on merits. 6. From the records, I noticed that assessee

Maharashtra Corporation Limited, Mumbai vs. Income Tax Officer Ward 4(2)(1), Mumbai

In the result the appeal filed by the assessee is allowed for statistical purposes

ITA 4459/MUM/2025[2016-17]Status: DisposedITAT Mumbai03 Nov 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankara.Ys: 2016-17

Section 250

which occurred in filing the appeal and construing the expression" sufficient cause" liberally we are inclined to condone the delay in filing the appeal before the Tribunal. Therefore we condone the delay and admit the appeal to be heard on merits. 6. From the records, we noticed that assessee

Raja Balarao Rustamrao Sewa Foundation, Mumbai vs. Commissioner of Income Tax- (Exemption), Pune

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

ITA 4348/MUM/2025[2025-26]Status: DisposedITAT Mumbai03 Nov 2025AY 2025-26

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 8Section 80G

vide order dated 16.01.2025 rejected the application for approval u/s 80G of Income Tax Act, 1961. The due date for filling appeal before the Tribunal was 31.03.2025. 8. Since the I am a senior citizen and not well versed with the compliances and not well versed with the online compliances

Raja Balarao Rustamrao Sewa Foundation, Mumbai vs. Commissioner of Income Tax - (Exemption), Pune

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

ITA 4347/MUM/2025[2025-26]Status: DisposedITAT Mumbai03 Nov 2025AY 2025-26

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 250Section 8Section 80G

Shree Agarsain Jan Sewa Sabha, New Delhi vs. Income Tax Officer, Ward

In the result, the appeal of the assessee is allowed

ITA 1010/DEL/2025[2021-22]Status: DisposedITAT Delhi03 Nov 2025AY 2021-22

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2021-22 Shree Agarsain Jan Sewa Vs. Income Tax Officer Sabha, Cu-164, Vishakha Enclave, Pritampura 110034 Pan No.Aacts3549J (Appellant) (Respondent)

Section 11Section 12ASection 12A(1)Section 139Section 143Section 143(1)Section 154

dated 30-06-2024 upholding the action of the CPC. Being aggrieved the order of the Ld. CIT(A), the assessee is in appeal before the tribunal. Ld. CIT(A) has observed in his order,: “7. In its reply the appellant has submitted that it had filed form

Satya Narain Bari, New Delhi vs. Dy.Commissioner of Income Tax Central Circle 20, New Delhi, Jhandewalan New Delhi

Appeal is hereby partly allowed

ITA 296/DEL/2024[2019-2020]Status: DisposedITAT Delhi03 Nov 2025AY 2019-2020

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandraassessment Year: 2019-20 Vs. Dcit, Sh. Satya Narain Bari, J324B, J Block 4, Pusta Central Circle-20, Kartar Nagar, Jagjit Nagar New Delhi S.O., East Delhi, Delhi Pan: Bbbpb2490Q (Appellant) (Respondent) Assessee By None Department By Sh. Mahesh Kumar, Cit(Dr)

Section 115BSection 132(1)Section 139Section 142(1)Section 144Section 153ASection 44ASection 69A

this group of appeal is hereby partly allowed.” This is what leaves the assessee/appellant aggrieved who has filed the instant appeal before the tribunal. 3. We have given thoughtful consideration to the assessee’s pleadings all along and Revenue’s vehement contentions reiterating their respective stands. Learned CIT(DR) first

G R C Garments Partnership Firm, Nandi Sahi, Buxi Bazar vs. ITO, Ward 1(1), Cuttack, Aayakar Bhawan, Shelter Chhak

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

ITA 383/CTK/2025[2018-19]Status: DisposedITAT Cuttack31 Oct 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 383/Ctk/2025 Assessment Year: 2018-2019 Grc Garments Partnership Firm,….…….,…Appellant Cuttack Sadar, Choudhury Bazar, Cuttack-753001, Odisha [Pan:Aaefg7391N] -Vs.- Income Tax Officer,……………………….…....Respondent Ward-1(1), Cuttack, Tulasipur, Cuttack-753008, Odisha Appearances By: Shri Diganta Das, Advocate, Appeared On Behalf Of The Assessee Shri Vijay Singh, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: September 03, 2025 Date Of Pronouncing The Order: October 31, 2025 O R D E R

Section 133(6)Section 142(1)Section 143(2)Section 68

been added under section 68 of the Act, by allowing this ground for statistical purposes. 5. On being aggrieved, the assessee preferred an appeal before the Tribunal. It was the submission of the ld. Counsel for the assessee that assessee is willing to prove the same with supporting evidences