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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

Deputy Commissioner of Income Tax, Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1515/KOL/2025[2017-18]Status: DisposedITAT Kolkata02 Jan 2026AY 2017-18
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

there is no infirmity in the same. 6. Aggrieved with both the orders of the authorities below, the assessee is in further appeal before the Tribunal. 7. Ld. AR vehemently submitted that the re-opening of assessment was made invalidly without satisfying the conditions precedent to issue of notice ... assessed the entire value of excess stock found at the time of survey by way of undisclosed income of the appellant. On appeal, Hon'ble Tribunal observed that the entire quantity of excess stock discovered in the course of survey operation could not beregarded as unexplained income of the appellant

Deputy Commissioner of Income Tax, Central Circle 3.1, Kolkata vs. Shakambhari Ispat & Power Limited, Kolkata

ITA 1436/KOL/2025[2016-17]Status: DisposedITAT Kolkata02 Jan 2026AY 2016-17
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

there is no infirmity in the same. 6. Aggrieved with both the orders of the authorities below, the assessee is in further appeal before the Tribunal. 7. Ld. AR vehemently submitted that the re-opening of assessment was made invalidly without satisfying the conditions precedent to issue of notice ... assessed the entire value of excess stock found at the time of survey by way of undisclosed income of the appellant. On appeal, Hon'ble Tribunal observed that the entire quantity of excess stock discovered in the course of survey operation could not beregarded as unexplained income of the appellant

M/S. Bms Sales Pvt. Ltd., Purulia vs. DCIT, Central Circle 3(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1199/KOL/2025[2019-2020]Status: DisposedITAT Kolkata02 Jan 2026AY 2019-2020

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Siddharth Jhajharia, ARFor Respondent: Shri Raja Sengupta, DR
Section 115JSection 132Section 132(1)Section 139(1)Section 142(1)Section 143(1)Section 143(2)Section 147Section 148

Sales Pvt. Ltd.; A.Y. 2019-20 2.3. Aggrieved with both the orders of the authorities below, the assessee is in further appeal before the Tribunal. 2.4. Ld. AR vehemently submitted that the re-opening of assessment was made invalidly without satisfying the conditions precedent to issue of notice

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, Central Circle 3(3), Kolkata

ITA 1198/KOL/2025[2021-2022]Status: DisposedITAT Kolkata02 Jan 2026AY 2021-2022
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

there is no infirmity in the same. 6. Aggrieved with both the orders of the authorities below, the assessee is in further appeal before the Tribunal. 7. Ld. AR vehemently submitted that the re-opening of assessment was made invalidly without satisfying the conditions precedent to issue of notice ... assessed the entire value of excess stock found at the time of survey by way of undisclosed income of the appellant. On appeal, Hon'ble Tribunal observed that the entire quantity of excess stock discovered in the course of survey operation could not beregarded as unexplained income of the appellant

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, Central Circle 3(3), Kolkata

In the result, appeals of the assessee are partly allowed and

ITA 1197/KOL/2025[2020-2021]Status: DisposedITAT Kolkata02 Jan 2026AY 2020-2021

Bench: Shri Rajesh Kumarand

Section 132Section 132(1)Section 147Section 148

there is no infirmity in the same. 6. Aggrieved with both the orders of the authorities below, the assessee is in further appeal before the Tribunal. 7. Ld. AR vehemently submitted that the re-opening of assessment was made invalidly without satisfying the conditions precedent to issue of notice ... assessed the entire value of excess stock found at the time of survey by way of undisclosed income of the appellant. On appeal, Hon'ble Tribunal observed that the entire quantity of excess stock discovered in the course of survey operation could not beregarded as unexplained income of the appellant

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, Central Circle 3(3), Kolkata

ITA 1196/KOL/2025[2018-2019]Status: DisposedITAT Kolkata02 Jan 2026AY 2018-2019
Section 132Section 132(1)Section 147Section 148

there is no infirmity in the same. 6. Aggrieved with both the orders of the authorities below, the assessee is in further appeal before the Tribunal. 7. Ld. AR vehemently submitted that the re-opening of assessment was made invalidly without satisfying the conditions precedent to issue of notice ... assessed the entire value of excess stock found at the time of survey by way of undisclosed income of the appellant. On appeal, Hon'ble Tribunal observed that the entire quantity of excess stock discovered in the course of survey operation could not beregarded as unexplained income of the appellant

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, CC - 3(3), Kolkata

ITA 1195/KOL/2025[2017-2018]Status: DisposedITAT Kolkata02 Jan 2026AY 2017-2018
Section 132Section 132(1)Section 147Section 148

there is no infirmity in the same. 6. Aggrieved with both the orders of the authorities below, the assessee is in further appeal before the Tribunal. 7. Ld. AR vehemently submitted that the re-opening of assessment was made invalidly without satisfying the conditions precedent to issue of notice ... assessed the entire value of excess stock found at the time of survey by way of undisclosed income of the appellant. On appeal, Hon'ble Tribunal observed that the entire quantity of excess stock discovered in the course of survey operation could not beregarded as unexplained income of the appellant

M/S. Shakambhari Ispat & Power Ltd., Kolkata vs. DCIT, Central Circle 3(3), Kolkata

ITA 1194/KOL/2025[2016-2017]Status: DisposedITAT Kolkata02 Jan 2026AY 2016-2017
For Appellant: Shri S. Jhajharia, FCAFor Respondent: Shri Sanat Kumar Raha, CIT-DR
Section 132Section 132(1)Section 147Section 148

there is no infirmity in the same. 6. Aggrieved with both the orders of the authorities below, the assessee is in further appeal before the Tribunal. 7. Ld. AR vehemently submitted that the re-opening of assessment was made invalidly without satisfying the conditions precedent to issue of notice ... assessed the entire value of excess stock found at the time of survey by way of undisclosed income of the appellant. On appeal, Hon'ble Tribunal observed that the entire quantity of excess stock discovered in the course of survey operation could not beregarded as unexplained income of the appellant

Smt Rashmi Ramesh Damani, Mumbai vs. DCIT, Circle 17(1), Mumbai

ITA 1129/MUM/2025[2014-15]Status: DisposedITAT Mumbai02 Jan 2026AY 2014-15

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri M. P. LohiaFor Respondent: Shri Vikas Chandra
Section 143(3)Section 271(1)(c)

looked after her commercial affairs who died on 04/06/2020 and her commercial affairs of her family including taxation matters remained unattended. Therefore, the appeal before the Tribunal could not filed within the prescribed time. On receipt of Penalty Order passed under Section 271(1)(c) of the Act, she contacted ... professional who advised her to file appeal before the Tribunal. In the aforesaid facts and circumstances the preset appeal came to be filed after a delay of more than 32 months. 3.2. In the case of Collector of Land Acquisition Vs. Mst. Katiji & others

M/S Sapphire Fintech Private Limited, Mumbai vs. DCIT-3(3)(1), Mumbai

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

ITA 595/MUM/2023[2014-15]Status: DisposedITAT Mumbai02 Jan 2026AY 2014-15

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankarm/S. Sapphire Fintech Private Limited 6Th Floor-1, Plot 165, 161/169 Hirachand Fulchand Trust Building, Perin Nariman Street, Fort, ............... Appellant Mumbai – 400001 Pan: Aahcs0312H V/S Deputy Commissioner Of Income Tax - 3(3)(1), ……………… Respondent Room No.609, Aayakar Bhavan, M.K. Road, Mumbai, Mumbai – 400020

For Appellant: Shri Mahaveer Jain, AdvFor Respondent: Shri Swapnil Choudhary, Sr.AR
Section 142(1)Section 143(2)Section 143(3)Section 250

Tribunal to the file of the AO for de novo adjudication. Further, we find that the assessee has also filed an appeal before the Tribunal for the assessment year 2012-13, and its outcome shall also have a bearing on the claim of 7 allowance of brought forward losses

Asst CIT Cir 29, Mumbai vs. Shoppers Stop Ltd, Mumbai

Accordingly, respectfully following the above decisions of the Tribunal, we confirm the aforesaid action of the CIT(A). All the grounds raised by the Revenue are, therefore, dismissed

ITA 6977/MUM/2014[2011-12]Status: DisposedITAT Mumbai02 Jan 2026AY 2011-12

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI PRABHASH SHANKAR (Accountant Member)

For Appellant: Shri Madhur Agrawala &For Respondent: Shri Swapnil Choudhary
Section 143(3)Section 14A

Being aggrieved by the order passed by the Learned CIT(A), both, the Assessee as well as the Revenue preferred appeal before the Tribunal against the Order passed by the Learned CIT(A). The appeal preferred by the Revenue (ITA No. 6977/Mum/2014) was dismissed vide Order, dated 23/12/2015 giving

Damanjeet Singh Oberoi, Raipur vs. DCIT, Circle-1(1), Raipur

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

ITA 317/RPR/2025[2015-16]Status: DisposedITAT Raipur01 Jan 2026AY 2015-16

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2015-16 Damanjeet Singh Oberoi Dcit, Circle 1(1), Raipur C/O Oberoi Tour & Travels, Shop No.1, Wali Mohd. Vs. Building, Kk Road, Moudhapara, Raipur – 492001 Pan: Aaepo3096L (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 133ASection 147Section 148Section 148ASection 69A

NFAC dismissed the appeal. 6. Aggrieved with such order of the Ld. CIT(A) / NFAC the assessee is in appeal before the Tribunal by raising the following grounds: Gr.No.1 "On the facts and circumstances of the case and in law, notice u/s148 dt.30- 6-21 (under old regime

Income Tax Officer-1(2), Raipur vs. Kanha Grain Process, Raipur

In the result, the appeal filed by the Revenue is dismissed

ITA 260/RPR/2025[2015-16]Status: DisposedITAT Raipur01 Jan 2026AY 2015-16

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2015-16 Ito, Ward 1(2), Raipur Kanha Grain Process Vs. Station Road, Tilda Neora, Raipur – 493114 Pan: Aaifk3222G (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(3)Section 147Section 148Section 148ASection 69C

thus, allowed the appeal of the assessee. 5. Aggrieved with such order of the Ld. CIT(A) / NFAC the Revenue is in appeal before the Tribunal by raising the following grounds: 1) Whether on the facts and in the circumstances of the case the Ld. CIT(A) was justified

Kamlesh Kukreja, Raipur vs. ITO, Ward-1(1), Raipur

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

ITA 119/RPR/2025[2016-17]Status: DisposedITAT Raipur01 Jan 2026AY 2016-17

Bench: Shri R. K. Panda & Shri Partha Sarathi Chaudhuryassessment Year : 2016-17 Kamlesh Kukreja Ito, Ward-1(1), Raipur Prop. Anmol Industries, Vs. Surajpura Road, Bhatapara, Raipur – 493118 Ahvpk6618C (Appellant) (Respondent) Assessee By : Shri Sunil Kumar Agrawal Department By : Dr. Priyanka Patel, Sr. Dr Date Of Hearing : 14-11-2025 Date Of Pronouncement : 01-01-2026 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri Sunil Kumar AgrawalFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 144Section 148Section 69C

NFAC, Delhi relating to assessment year 2016-17. 2. There is a delay of 156 days in filing of this appeal before the Tribunal for which the assessee has filed a condonation application along with an affidavit explaining the reasons for such delay. The Ld. Counsel for the assessee submitted ... dismissed the appeal filed by the assessee. 11. Aggrieved with such order of the Ld. CIT(A) / NFAC the assessee is in appeal before the Tribunal by raising the following grounds: 5 Gr.No.1: "On the facts and circumstances of the case and in law, notice u/s 148 dt.30-6-21

Raisoni Bagrecha Diamonds Private Limited, Jalgaon vs. Pne-C-(25)(1), Circle 1, Jalgaon

In the result, the appeals of the assessee in ITA No

ITA 2550/PUN/2025[2016-2017]Status: DisposedITAT Pune01 Jan 2026AY 2016-2017

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.2548 & 2550/Pun/2025 धििाारण वर्ा / Assessment Year : 2015-16 & 2016-17 Raisoni Bagrecha Diamonds Pne-C-(25)(1), Pvt. Ltd. 288, Baliram Peth, Circle-1, Jalgaon Jalgaon-425001, Maharashtra Vs. Pan : Aadcr 7439 N अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Sanjay T. Tupe, Ca Department By : : Smt. Indira R. Adakil –Addl. Cit Date Of Hearing : 04-12-2025 Date Of Pronouncement : 01-01-2026 आदेश / Order Per Astha Chandra, Jm : The Appeals Filed By The Assessee Is Directed Against The Separate Order(S) Both Dated 14.08.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2015-16 & 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal :-

For Appellant: Shri Sanjay T. Tupe, CAFor Respondent: : Smt. Indira R. Adakil –Addl. CIT
Section 145ASection 69

absence of any credible rebuttal filed by the assessee to the findings of the Ld. AO. 5. Aggrieved, the assessee is in appeal before the Tribunal and all the grounds of appeal for AY 2015-16 and 2016-17 reproduced above relate thereto. 6. The Ld. AR submitted that

Raisoni Bagrecha Diamonds Private Limited, Jalgaon vs. Pne-C-(25)(1), Circle 1, Jalgaon

In the result, the appeals of the assessee in ITA No

ITA 2548/PUN/2025[2015-2016]Status: DisposedITAT Pune01 Jan 2026AY 2015-2016

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.2548 & 2550/Pun/2025 धििाारण वर्ा / Assessment Year : 2015-16 & 2016-17 Raisoni Bagrecha Diamonds Pne-C-(25)(1), Pvt. Ltd. 288, Baliram Peth, Circle-1, Jalgaon Jalgaon-425001, Maharashtra Vs. Pan : Aadcr 7439 N अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Sanjay T. Tupe, Ca Department By : : Smt. Indira R. Adakil –Addl. Cit Date Of Hearing : 04-12-2025 Date Of Pronouncement : 01-01-2026 आदेश / Order Per Astha Chandra, Jm : The Appeals Filed By The Assessee Is Directed Against The Separate Order(S) Both Dated 14.08.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2015-16 & 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal :-

For Appellant: Shri Sanjay T. Tupe, CAFor Respondent: : Smt. Indira R. Adakil –Addl. CIT
Section 145ASection 69

absence of any credible rebuttal filed by the assessee to the findings of the Ld. AO. 5. Aggrieved, the assessee is in appeal before the Tribunal and all the grounds of appeal for AY 2015-16 and 2016-17 reproduced above relate thereto. 6. The Ld. AR submitted that

Chintan Harshad Kanakia, Mumbai vs. ITO Ward 42(1)(1), Mumbai

In the result, ground No.3 of appeal is allowed

ITA 2822/MUM/2025[2015-16]Status: DisposedITAT Mumbai01 Jan 2026AY 2015-16

Bench: Shri Pawan Singhsmt Renu Jauhriassessment Year: 2015-16 (Hybrid Hearing) Chintan Harshad Kanakia, Ito Ward 42 (1)(1) Room No. 103, Sacovar Apt., Sagar Complex, 703, Kautilya Bhavan, Vs. Saibaba Nagar, Borivali (W), Bkc, Mumbai -400051 Mumbai Pan – Agnpk6023E

Section 10(38)Section 132Section 143(2)Section 148Section 148ASection 151ASection 234BSection 254(1)Section 271(1)(c)

critical evidence and inconsistencies found in evidence of assessee and upheld the action of Assessing Officer. Further aggrieved the assessee has filed present appeal before the Tribunal. 7. We have heard the submissions of Ld. Authorised Representative (AR) of the Assessee and the Ld. Senior departmental representative

Murubhai Hardasbhai Vasara, Porbandar vs. ITO WD 2 (4), Porbandar

In the result, the appeal of the assessee is partly allowed in above terms

ITA 554/RJT/2025[2017-18]Status: DisposedITAT Rajkot31 Dec 2025AY 2017-18

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita No. 554/Rjt/2025 िनधा"रण वष" /Assessment Year: (2017-18) Murubhai Hardasbhai Vasara Income-Tax Officer, Ward-2(4), Porbandar-360550 17, Main Bazar, Village Rana बनाम /Vs. Kandorna, Ranavav, Porbandar- 360 550 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Adqpv 9119 C (Appellant) (Respondent)

For Appellant: Shri Suresh Tejwani, Ld. ARFor Respondent: Shri Gopi Nath Chaubey Ld. Sr. DR
Section 133(6)Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250

totaling to Rs.36,13,910/- was sustained by ld.CIT(A). 11.Aggrieved by the order of Ld.CIT(A) assessee is in appeal before the Tribunal. Murubhai H. Vasara 12. Learned Counsel for the assessee, vehemently argued that during appellate proceedings as well as assessment proceedings, assessee submitted cash flow statement, proof

Vipul Arjanbhai Parmar, Mangrol vs. Income Tax Officer, Ward -1, Junagadh

In the result, appeal filed by the assessee is allowed

ITA 217/RJT/2025[2010-11]Status: DisposedITAT Rajkot31 Dec 2025AY 2010-11

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.217/Rjt/2025 िनधा"रण वष"/Assessment Year : 2010-11 बनाम/ Vipul Arjanbhai Parmar Income Tax Officer Vs C/O. Sarda & Sarda (Ca), Sakar, Ward – 1, Junagadh 1St Floor, Dr. Radha-Krishnan Road, Opp. Rajkumar College, Rajkot, Gujarat - 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ditpp9286B (अपीलाथ"/Assessee) (""थ"/Respondent)

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(3)Section 250

entirely depending upon the advice of the Advocate. The Advocate of the assessee did not take care to file the appeal before the Tribunal, on time. Therefore, such delay has occurred, due to mistake of the advocate of the assessee, which may kindly be condoned. Therefore, in this process delay ... considered opinion that assessee was under a bona fide belief that the impugned order of Pr. CIT was not appealable before this Tribunal since they were not advised by their Tax Consultants about this legal right. Later on, when a Senior Lawyer advised them to file an appeal, the assessees

Ashish Kumar, Shravasti vs. ITO-1, Bahraich

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

ITA 736/LKW/2025[2017-18]Status: DisposedITAT Lucknow31 Dec 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Ashish Kumar V. The Ito-1 S/O Onkar Nath, Bardehra Bahraich Bharigan, Pathpur, Ekauna Shravasti (U.P) Tan/Pan:Deqpk8563B (Applicant) (Respondent) Applicant By: Shri Raghunath Mishra, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 31.01.2024, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2017-18. 2.0 The Brief Facts Of The Case Are That The Assessee Had Not Filed His Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Made Cash Deposits Of Rs.11,50,000/- In His Bank Account No.4666020000005 Maintained With Bank Of Baroda, Bahraich, During The Demonetization Period. The Case Of The Assessee Was Reopened Under Section 147 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) After Issuing Notice To The Assessee Under Section 148 Of The Act. However, There Was No Response From The Side Of The Assessee To The Notice Issued Under

For Respondent: Shri R.R.N. Shukla, D.R
Section 115BSection 144Section 147Section 148Section 69

Authorized Representative for the assessee (Ld. A.R.) submitted that there is a delay of 565 days in filing the appeal before the Tribunal. He further submitted that the assessee had filed an application dated 18.10.2025 for condonation of delay, duly supported by an Affidavit and Medical Certificate, stating therein that ... No.736/LKW/2025 Page 4 of 6 declared fit on 17.10.2025 and that owing to this fact, the assessee could not file the appeal before the Tribunal within the stipulated period. The prayer of the Ld. A.R. was that the delay caused in filing the appeal was not deliberate and that