“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

Earth Charitable Foundation, Pune vs. CIT(Exemtpiton), Pune

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

ITA 846/PUN/2025[-]Status: DisposedITAT Pune17 Dec 2025

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

For Appellant: Smt. Deepa KhareFor Respondent: Shri Amol Khairnar

Section 12A(1)(ac)Section 40Section 8

Income Tax Act, 1961 (the “Act”). 2. There is a delay of 124 days in filing of this appeal before the Tribunal for which the assessee has filed an application for condonation of delay along with affidavit explaining the reasons for such delay. He submitted that the delay ... rival contentions and perused the record. It is an admitted fact that there is a delay of 124 days in filing of the appeal before the Tribunal. The Ld. Counsel for the assessee has filed an affidavit of the assessee stating the reason for such delay which are as under

Ashok Hirachand Shah, Panvel vs. Assessing Officer Ward 2, Panvel

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

ITA 812/PUN/2025[2011-12]Status: DisposedITAT Pune17 Dec 2025AY 2011-12

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.812/Pun/2025 धििाारण वर्ा / Assessment Year : 2011-12 Ashok Hirachand Shah, Assessing Officer, Plot No. 4, Mangal Bunglow, Ward – 2, Panvel Road No. 5, Sector No. 19, Vs. New Panvel, Tal.-Panvel-410206 Pan : Acdps4800M अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Ajinkya Shah Department By : Shri Rajesh Gawali Date Of Hearing : 09-12-2025 Date Of 17-12-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 20.01.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. Denial Of Natural Justice & Proper Opportunity The Learned Commissioner Of Income Tax (Appeals) Erred In Dismissing The Appeal Without Considering That The Appellant Was Denied Proper Opportunity & Natural Justice During The Assessment Proceedings. The Assessing Officer Called For Information At The Far End Of The Assessment Proceedings On 19/11/2018 & Despite The Appellant'S Authorized Representative Submitting The Details On 19/12/2018, The Ao Failed To Discuss Or Consider The Same. The Matter Ought To Have Been Remanded Back For Fresh Adjudication To Allow Proper Analysis Of The Transactions. 2. Addition Without Specifying The Section The Cit(A) Erred In Upholding The Addition Of Rs. 1,49,05,289/- Made By The Ao Without Specifying The Section Under Which The Addition Was Made. The Non-Mention Of The Specific Section Renders The Assessment Order Bad In Law, As It Violates The Principles Of Natural Justice & Transparency In Taxation. 3. Failure To Discharge Onus Under Section 69A

For Appellant: Shri Ajinkya ShahFor Respondent: Shri Rajesh Gawali

Section 147Section 69A

appellant has nothing more to say on merits of the matter. The ground of appeal is dismissed.” 5. Dissatisfied, the assessee is in appeal before the Tribunal and all the grounds of appeal relate thereto. 6. The assessee’s son Mr. Ajinkya Shah appeared for the assessee. He submitted that

Shree Digmber Jain Trust Wagholi, Pune vs. CIT(Exemption), Pune

In the result, both the appeals in ITA Nos

ITA 2511/PUN/2025[-]Status: DisposedITAT Pune17 Dec 2025

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

For Appellant: Shri Premal GandhiFor Respondent: Smt. Indira R. Adakil

Section 12ASection 12A(1)(ac)Section 80G

heard together and are being disposed of by this common order. 2. There is a delay of 121 days in filing of this appeal before the Tribunal for which the assessee has filed an affidavit explaining the reasons for such delay. On perusal of the same, we are satisfied that ... Income Tax Act, 1961 is hereby cancelled.” 5. Aggrieved with such order of the Ld. CIT(E), the assessee is in appeal before the Tribunal by raising the following grounds: “1. That the order dated 07.04.2025 passed by the learned CIT (Exemption), Pune rejecting the application and cancelling the provisional

Shree Digmber Jain Trust Wagholi, Pune vs. CIT(Exemption), Pune

In the result, both the appeals in ITA Nos

ITA 2510/PUN/2025[-]Status: DisposedITAT Pune17 Dec 2025

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

For Appellant: Shri Premal GandhiFor Respondent: Smt. Indira R. Adakil

Section 12ASection 12A(1)(ac)Section 80G

DCIT-Circle 1(1), Pune, Swargate Pune vs. Ansec Human Resource Services Limited, Pune

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

ITA 1309/PUN/2025[2018-19]Status: DisposedITAT Pune17 Dec 2025AY 2018-19

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

For Appellant: Smt. Deepa KhareFor Respondent: Shri A D Kulkarni

Section 142(1)Section 143(3)Section 80J

number 118672441160818 So, the contention of the appellant was genuine. Hence, me of the appeal is allowed.” 5. Dissatisfied, the assessee is in appeal before the Tribunal and all the grounds of appeal relate thereto. 6. The Ld. DR supported the order of the Ld. AO. He submitted that since

Dharambhaskar Rashtrasant Shri Pichlegavkar Maharaj Foundation, Pune vs. CIT Exemption, Pune

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

ITA 1060/PUN/2025[N.A.]Status: DisposedITAT Pune17 Dec 2025

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

For Appellant: Shri Jasraj SutarFor Respondent: Shri Amol Khairnar

Section 12ASection 12A(1)(ac)

12AB read with section 12A(1)(ac) (vi) of the Income Tax Act, 1961 is hereby cancelled.” 5. Aggrieved, 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. CIT(E) has rejected

M/S B.N. Dutta, Jamshedpur vs. DCIT, Cir. 2, Durgapur

The appeal of the assessee is allowed for statistical purposes

ITA 705/KOL/2024[2011-12]Status: DisposedITAT Kolkata17 Dec 2025AY 2011-12

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.705/Kol/2024 Assessment Year: 2011-12 M/S B. N. Dutta ….…………………………………………………..………….……Appellant Head Office: 518, G Road, Sonari West Layout, Jamshedpur, Jharkhand – 831011. [Pan: Aadfb0648J] Vs. Dcit, Circle-2, Durgapur……..……....….….. ……………….........……...…..…..Respondent Appearances By: Shri D. Khasnobis, Ca & None Appeared On Behalf Of The Appellant. Shri H. Robindro Singh, Addl. Cit - Dr & None Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2025 & December 17, 2025 Date Of Pronouncing The Order : December 17, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 13.02.2024 Of The Commissioner Of Income Tax (Appeals), Indore [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is Partnership Firm & Engaged In The Business Of Civil Construction & Maintenance Of Civil Structures Inside Stell Plants. For The Assessment Year 2011-12, The Assessee Filed Its Return On 30.09.2011 By Declaring Total Income Of Rs.36,58,080/- & Total Tax & Cess Liability Of Rs.11,30,347/- Was Discharged In Full Resulting In A Refund Of Rs.12,520/-. The Return Of The Assessee Was Processed By The Cpc U/S 143(1) Of The Act On 27.01.2012. The Assessee Did Not Receive Any Information From The Cpc Either Directly By Way Of Service Of Physical Copy Of The Same Or From The Then Authorised Representative Namely Mr. S. N. Gupta. Due To Non-Receipt Of

Section 143(1)Section 249(3)Section 250

decided on merits. In the result, the appeal of the appellant is dismissed.” 6. Dissatisfied with the above order, the assessee preferred an appeal before this Tribunal stating that the appeal of the assessee was dismissed by the ld. CIT(A) simply on technical ground which was not correct ... case of Sanjay Kr. Choudhury vs. DCIT in IT(SS) Nos.3 to 8/Ran/2020 allowed a delay of 1130 days in filing the appeal before the Tribunal on the part of the assessee by holding as under: “11. After hearing the rival contentions and perusing the material on record, we find

Aravindan Rengasamy, Chennai vs. ACIT (International Taxation), Madurai

In the result, the appeal of the assessee is allowed for statistical purposes and the Stay application is dismissed as infructuous

ITA 3297/CHNY/2025[2019-20]Status: DisposedITAT Chennai17 Dec 2025AY 2019-20

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3297/Chny/2025 & S.A No.115/Chny/2025 िनधा%रण वष% /Assessment Year: 2019-20 Aravindan Rengasamy, The Asst. Commissioner Of Income C/O. Sundaram & Narayanan, Vs. Tax (International Taxation), Chartered Accountants, Madurai. 18 Balaiah Avenune, Luz Churchroad, Mylapore, Chennai – 600 004. Pan: Apupr 6827B

For Appellant: Mr.K. Meenakshi Sundaram, C.A *+For Respondent: Ms. E.Pavuna Sundari, CIT

Section 127Section 147Section 148Section 148ASection 151ASection 69

ground that the assessee has not raised any objection against the addition made by the A.O. The assessee is in appeal before the Tribunal against the final order of assessment passed by the A.O pursuant to the direction of the DRP. ITA No.3297/Chny/2025 & SA No.115/Chny/2025 Aravindan Rengasamy :- 5 -: 4. There ... delay of 232 days in filing the appeal before the Tribunal and the assessee filed an affidavit in this regard. The assessee in the petition for condonation of delay has submitted that the assessee has filed the appeal against the final order of assessment inadvertently before

Chinnakannu Sundhar, Ponneri vs. ITO, Ncw-10(3), Chennai

In the result, the appeal of the assessee is allowed for statistical purposes and the Stay application is dismissed as infructuous

ITA 3190/CHNY/2025[2018-19]Status: DisposedITAT Chennai17 Dec 2025AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3190/Chny/2025 & S.A No.124/Chny/2025 िनधा$रण वष$ /Assessment Year: 2018-19 Chinnakkannu Sundhar, The Income Tax Officer, Peruncherry, Vs. Non Corporate Ward-10(3), Panchetty, Ponneri-600 052. Chennai. Pan: Eyrps 6145H

For Appellant: Ms. S. Deepika, AdvocateFor Respondent: Ms. Babitha, JCIT

Section 148Section 2(14)Section 250

material on record, we are of the view that there is a reasonable and sufficient cause for the delay in filing the appeal before the Tribunal. Therefore following the Hon’ble Supreme Court decision in the case of Collector, Land Acquisition Vs. MST.Katiji & Ors., (167 ITR 471) (SC), we condone ... ground that the assessee failed to respond to the notices and did not file any additional details. The assessee is in appeal before the Tribunal against the order of CIT(A). 4. The Ld. Authorized Representative (AR) submitted that the assessee along with his brother inherited certain agricultural land from

Raju Chandrasekar, Oduvanpatti, Tiruppattur (Tk) vs. Income Tax Officer, Ward-1, Karaikudi, Sekkalai Road

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

ITA 3000/CHNY/2025[2015-2016]Status: DisposedITAT Chennai17 Dec 2025AY 2015-2016

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 3000/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Ms. R. Anitha, Addl.CIT

Section 144BSection 147Section 148Section 148ASection 250

hereinafter called ‘the Act’). The relevant Assessment Year is 2015-16. :- 2 -: 2. There is a delay of 28 days in filing this appeal before the Tribunal. The assessee has filed a petition for condonation of delay along with the supporting affidavit stating therein the reasons for belated filing

Haridoss Gnanaprakasam, Chennai vs. ITO, Non Corporate Circle-22(1), Tambaram

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

ITA 2263/CHNY/2025[2018-19]Status: DisposedITAT Chennai17 Dec 2025AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2263/Chny/2025 िनधा#रण वष# /Assessment Year: 2018-19

For Appellant: Mr. R. Raj Kapoor, C.A ()For Respondent: Ms. Latchana, JCIT

Section 250

confirmed the additions/disallowances for the same reason that the assessee did not file any response or details. The assessee is in appeal before the Tribunal against the order of the CIT(A). ITA No2263 /Chny/2025 Haridoss Gnanaprakasam :- 5 -: 3. There is a delay of 74 days in filing the appeal ... material on record, we are of the view that there is a reasonable and sufficient cause for the delay in filing the appeal before the Tribunal. Therefore following the Hon’ble Supreme Court decision in the case of Collector, Land Acquisition Vs. MST.Katiji & Ors., (167 ITR 471) (SC), we condone

Syed Nazeer Syed Fayaz, Erode vs. ITO, Ward-2(1), Erode

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

ITA 2189/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Dec 2025AY 2017-18

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2189/Chny/2025 िनधा%रण वष% /Assessment Year: 2017-18

For Appellant: Mr. S. Bhupendran, AdvocateFor Respondent: Ms. Babitha, JCIT

Section 14Section 143(3)Section 250

dismissed the appeal stating that there was no sufficient cause demonstrated by the assessee to condone the delay. The assessee is in appeal before the Tribunal against the order of the FAA. 5. We have heard the parties and perused the materials available on record. From the perusal

M T Krishne Gowda, Hassan vs. Income Tax Officer, Ward-1 & Tps, Hassan

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

ITA 832/BANG/2025[2020-21]Status: DisposedITAT Bangalore17 Dec 2025AY 2020-21

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2020-21 Shri. M. T. Krishne Gowda, Vs. Ito, Lakshmi Stone Crushing Industries, Ward – 1& Tps, Muduganur Arkalgud, Hassan. Hassan – 573 201, Karnataka. Pan : Arupk 5347 F Appellant Respondent Assessee By : Shri. Mahesh R Uppin, Ar Revenue By : Shri. Balusamy N, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 17.11.2025 Date Of Pronouncement : 17.12.2025

For Appellant: Shri. Mahesh R Uppin, ARFor Respondent: Shri. Balusamy N, JCIT(DR)(ITAT), Bangalore

Section 115BSection 68

Roshan Di Hatti Vs. CIT (SC) 107 ITR 938, dismissed appeal of the assessee. 4. Aggrieved from the above Order, assessee filed appeal before the Tribunal. The learned Counsel reiterated the submissions made before the lower authorities and submitted that the entire land ownership was proved and copies

Vikrant, Shamli vs. Income Tax Officer, Ward-3(1)(4), Shamli

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

ITA 5129/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Ms. Ankush Kalra, SR. DR

Section 144BSection 147Section 148Section 184Section 234ASection 250Section 271(1)

/DEL/2025 Vikrantl VS. ITO Ward-3(1)(4) Shamli Further aggrieved, the assessee has filed present appeal before the Tribunal. 3. Before us, Ld. AR has requested to restore the matter to the Ld. AO for fresh adjudication after affording due opportunity as the order has been passed in gross

Vikrant, Shamli vs. Income Tax Officer, Ward-3(1)(4), Shmali

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

ITA 5128/DEL/2025[2016-17]Status: DisposedITAT Delhi17 Dec 2025AY 2016-17

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Ms. Ankush Kalra, SR. DR

Section 144BSection 147Section 148Section 184Section 234ASection 250Section 271(1)

Vikrant, Shamli vs. Income Tax Officer, Ward-3(1)(4), Shamli

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

ITA 5127/DEL/2025[2015-16]Status: DisposedITAT Delhi17 Dec 2025AY 2015-16

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Ms. Ankush Kalra, SR. DR

Section 144BSection 147Section 148Section 184Section 234ASection 250Section 271(1)

Vikrant, Shamli vs. Income Tax Officer, Ward-3(1)(4), Shamli

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

ITA 5126/DEL/2025[2014-15]Status: DisposedITAT Delhi17 Dec 2025AY 2014-15

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Ms. Ankush Kalra, SR. DR

Section 144BSection 147Section 148Section 184Section 234ASection 250Section 271(1)

Vikrant, Shamli vs. Income Tax Officer, Ward-3(1)(4), Shamli

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

ITA 5125/DEL/2025[2013-14]Status: DisposedITAT Delhi17 Dec 2025AY 2013-14

Bench: Shri Vimal Kumar & Smt. Renu Jauhri

For Appellant: Shri Ankit Gupta, AdvFor Respondent: Ms. Ankush Kalra, SR. DR

Section 144BSection 147Section 148Section 184Section 234ASection 250Section 271(1)

Pristine Mega Logistics Park Pvt. Ltd., Delhi vs. DCIT Circle- 19(1), New Delhi

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

ITA 1450/DEL/2025[2022-23]Status: DisposedITAT Delhi17 Dec 2025AY 2022-23

Bench: Shri Anubhav Sharma& Shri Amitabh Shukla[Assessment Year: 2022-23] M/S Pristine Mega Logistics Dy. Commissioner Of Income Tax, Park Pvt. Ltd., Cpc Bangalore, 3Rd Floor, Commercial Plaza, Vs Circle-19(1), New Delhi Wing B, Radisson Hotel, Mahipalpur, New Delhi-110037 Pan:Aagcp8465R Appellant Respondent Assessee By Shri Ashok Jain, Ca Revenue By Shri Dayainder Singh Sidhu, Cit(Dr) Date Of Hearing 10.12.2025 Date Of Pronouncement 17.12.2025

Section 139(1)Section 143(1)(a)Section 143(3)Section 80Section 80I

Contimeters Electricals (P.) Ltd. as at 317 ITR 249 held as under:- “…...5. Being aggrieved by the said order, the assessee preferred an appeal before the Tribunal which was allowed by the Tribunal by virtue of the impugned order. The Tribunal took the view that the provisions of section

Gayathri Global Resources Private Limited, Jamshedpur vs. ITO Ward (1), Jamshedpur

In the result, both the appeals are allowed for statistical purposes

ITA 96/RAN/2025[2014-15]Status: DisposedITAT Ranchi16 Dec 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.456/Ran/2024 Assessment Year: 2013-14 Gayatri Global Pvt. Ltd …………….…….…............................……….……Appellant 153, Kamani Centre, Bistupur, Jharkhand-831001. [Pan: Aadcg3732B] Vs. Nfac, New Delhi…….....………...….…..….........……........……...…..…..Respondent I.T.A. No.96/Ran/2025 Assessment Year: 2014-15 Gayatri Global Pvt. Ltd …………….…….…............................……….……Appellant 153, Kamani Centre, Bistupur, Jharkhand-831001. [Pan: Aadcg3732B] Vs. Nfac, New Delhi…….....………...….…..….........……........……...…..…..Respondent Appearances By: Shri Manish Agarwal, Ca, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 11, 2025 Date Of Pronouncing The Order : December 16, 2025 Order Per Sonjoy Sarma: These Two Appeals Are Filed By The Assessee For The Assessment Years 2013–14 & 2014–15. Since The Issues Involved, The Assessment Proceedings & The Additions Made Are Common & On Identical Issues, Both The Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order. For The Sake Of Convenience, We First Take Up

Section 115BSection 144Section 147Section 148Section 68

where Ld. AO sustained the assessment order primarily on the ground of non-compliance by the assessee. 4. Aggrieved, the assessee is in appeal before the Tribunal. The learned AR submitted that adequate opportunity of being heard was not granted to the assessee and prayed that the matter be restored