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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

DCIT, Central Circle, Dehradun vs. Graphic Era Educational Society, Dehradun

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

ITA 1848/DEL/2018[2011-12]Status: DisposedITAT Dehradun10 Mar 2026AY 2011-12

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANISH AGARWAL (Accountant Member)

Section 153ASection 153A(1)(b)Section 250Section 69

expenditure for which no bills were raised. 3. In first appeal, Ld. CIT(A) deleted both the additions therefore the Revenue is in appeal before the Tribunal. 4. In Ground of appeal Nos. 1 & 2, the Revenue challenged the deletion of addition of INR 10,03,361/-. 5. In support

Gurudwara Sant Bhai Narain Singh Ji, Panipat, Haryana India vs. ITO, Exemptions Ward Ambala

The appeal of the assessee is allowed for statistical purposes

ITA 285/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh10 Mar 2026AY 2022-23

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 285/Chd/2025 "नधा"रण वष" / Assessment Year: 2022-23 Gurudwara Sant Bhai Narain The Ito (Exemptions), Singh Ji, Ward -7, Vs Ward, Sonali Road, Panipat. Ambala. "थायी लेखा सं./Pan No: Aaatg2719E अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Nitin Kanwar & Shri Shivam Jain, Advocates Revenue By : Shri Manav Bansal, Cit Dr Date Of Hearing : 24.02.2026 Date Of Pronouncement : 10.03.2026 Hybrid Hearing O R D E R

For Appellant: Shri Nitin Kanwar & Shri Shivam Jain, AdvocatesFor Respondent: Shri Manav Bansal, CIT DR
Section 12ASection 12A(1)(ac)

Hearing : 24.02.2026 Date of Pronouncement : 10.03.2026 HYBRID HEARING O R D E R PER RAJ PAL YADAV, VP The assessee is in appeal before the Tribunal against the order of the ld. Commissioner of Income Tax (Exemptions) [in short ‘the CIT (E)’] dated 27.09.2024. 2. The grievance of the assessee

Dada Motor Enterprises LLP, Ludhiana vs. Deputy Commissioner of Income Tax, Circle-1, Ludhiana

In the result, appeal of the assessee is allowed

ITA 25/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh10 Mar 2026AY 2023-24

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 25/Chd/2025 "नधा"रण वष" / Assessment Year: 2023-24 Dada Motor Enterprises Llp, Vs The Dcit, Savitri-Ii, Dholewal Chowk, Circle-1, Millerganj, S.O. Ludhiana. Ludhiana. "थायी लेखा सं./Pan No: Aarfd7944D अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Parikshit Aggarwal, Ca Revenue By : Shri Vivek Vardhan, Addl.Cit, Sr.Dr Date Of Hearing : 24.02.2026 Date Of Pronouncement : 10.03.2026 Hybrid Hearing O R D E R Per Rajpal Yadav, Vp

For Appellant: Shri Parikshit Aggarwal, CAFor Respondent: Shri Vivek Vardhan, Addl.CIT, Sr.DR
Section 143(1)Section 80J

Date of Hearing : 24.02.2026 Date of Pronouncement : 10.03.2026 HYBRID HEARING O R D E R PER RAJPAL YADAV, VP The assessee is in appeal before the Tribunal against the order of the ld. Commissioner of Income Tax (Appeals) [in short ‘the CIT (A)’] dated 25.11.2024 passed for assessment year

Punam Rani, Kurukshetra, Haryana vs. Income Tax Officer, Kurukshetra, Haryana

In the result, the appeal is allowed for statistical purposes

ITA 1620/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh10 Mar 2026AY 2023-24

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri B.M. Monga, Advocate, and Shri Rohit Kaura, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

additions made by the Assessing Officer and dismissed the appeal. 4. Against the order of the Ld. CIT(A) the assessee preferred in appeal before the Tribunal. 5. At the time of hearing before us, the assessee moved an application seeking adjournment. The reasons stated in the application have been

Abhinav Doda, Ellenabad, Sirsa vs. Income Tax Officer, Ward-1, Sirsa

In the result, appeal is allowed

ITA 1333/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh10 Mar 2026AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1333/Chd/2025 "नधा"रण वष" / Assessment Year: 2017-18 Shri Abhinav Doda, The Ito, 32, Huda Colony, Ellenabad, Vs Ward-1, Sirsa. Sirsa. "थायी लेखा सं./Pan No: Caipd4768C अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashwani Kumar & Ms. Deepali Aggarwal, Cas Revenue By : Shri Vivek Vardhan, Addl. Cit Sr.Dr Date Of Hearing : 24.02.2026 Date Of Pronouncement : 10.03.2026 Physical Hearing

For Appellant: Shri Ashwani Kumar & Ms. Deepali Aggarwal, CAsFor Respondent: Shri Vivek Vardhan, Addl. CIT Sr.DR
Section 143(2)

Date of Hearing : 24.02.2026 Date of Pronouncement : 10.03.2026 PHYSICAL HEARING O R D E R PER RAJPAL YADAV, VP The assessee is in appeal before the Tribunal against the order of the ld. Commissioner of Income Tax (Appeals) [in short ‘the CIT (A)’] dated 29.08.2025 passed for assessment year

Kewal Krishan, Chandigarh vs. Joa DCIT/ACIT/JCIT(OSD)(Central Circle) 1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1275/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh10 Mar 2026AY 2023-24

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं . / ITA No. 1269 To 1272/Chd/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Το 2023-24 Chandigarh Royale City Promoters बनाम JAO DCIT/ACIT/JCIT (OSD) Central Private Limited, Circle-1, Chandigarh-160017 SCO-44, Sector-20C, Chandigarh स्थायी लेखा सं./ PAN NO: AAECC3999H अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1273 Το 1275/Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2020-21, 2021-22 & 2023-2

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

against the 20% applied by the Assessing Officer. 9. Against the order of the Ld. CIT(A) the assessee preferred in appeal before the Tribunal. 10. During the course of hearing the Ld. Counsel of the assessee did not press the ground No. 4 & 5 of the appeals and argued

Kewal Krishan Chandigarh, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) (Central Circle) 1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1274/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh10 Mar 2026AY 2021-22
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

against the 20% applied by the Assessing Officer. 9. Against the order of the Ld. CIT(A) the assessee preferred in appeal before the Tribunal. 10. During the course of hearing the Ld. Counsel of the assessee did not press the ground No. 4 & 5 of the appeals and argued

Kewal Krishan, Chandigarh vs. Jao DCIT/ACIT JCIT (OSD)(Central Circle)-1, Chandigarh.

In the result, all the above appeals are partly allowed

ITA 1273/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh10 Mar 2026AY 2020-21
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

against the 20% applied by the Assessing Officer. 9. Against the order of the Ld. CIT(A) the assessee preferred in appeal before the Tribunal. 10. During the course of hearing the Ld. Counsel of the assessee did not press the ground No. 4 & 5 of the appeals and argued

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1272/CHANDI/2025[2023-2024]Status: DisposedITAT Chandigarh10 Mar 2026AY 2023-2024

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

against the 20% applied by the Assessing Officer. 9. Against the order of the Ld. CIT(A) the assessee preferred in appeal before the Tribunal. 10. During the course of hearing the Ld. Counsel of the assessee did not press the ground No. 4 & 5 of the appeals and argued

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1271/CHANDI/2025[2022-2023]Status: DisposedITAT Chandigarh10 Mar 2026AY 2022-2023
For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

against the 20% applied by the Assessing Officer. 9. Against the order of the Ld. CIT(A) the assessee preferred in appeal before the Tribunal. 10. During the course of hearing the Ld. Counsel of the assessee did not press the ground No. 4 & 5 of the appeals and argued

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT (OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1270/CHANDI/2025[2021-2022]Status: DisposedITAT Chandigarh10 Mar 2026AY 2021-2022

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं . / ITA No. 1269 To 1272/Chd/2025 निर्धारण वर्ष / Assessment Year : 2020-21 Το 2023-24 Chandigarh Royale City Promoters बनाम JAO DCIT/ACIT/JCIT (OSD) Central Private Limited, Circle-1, Chandigarh-160017 SCO-44, Sector-20C, Chandigarh स्थायी लेखा सं./ PAN NO: AAECC3999H अपीलार्थी/Appellant प्रत्यर्थी / Respondent आयकर अपील सं. / ITA No. 1273 Το 1275/Chd/ 2025 निर्धारण वर्ष / Assessment Year : 2020-21, 2021-22 & 2023-2

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

against the 20% applied by the Assessing Officer. 9. Against the order of the Ld. CIT(A) the assessee preferred in appeal before the Tribunal. 10. During the course of hearing the Ld. Counsel of the assessee did not press the ground No. 4 & 5 of the appeals and argued

Chandigarh Royale City Promoters Private Limited, Chandigarh vs. Jao DCIT/ACIT/JCIT(OSD) Central Circle-1, Chandigarh

In the result, all the above appeals are partly allowed

ITA 1269/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh10 Mar 2026AY 2020-2021

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR
Section 144BSection 148Section 151A

against the 20% applied by the Assessing Officer. 9. Against the order of the Ld. CIT(A) the assessee preferred in appeal before the Tribunal. 10. During the course of hearing the Ld. Counsel of the assessee did not press the ground No. 4 & 5 of the appeals and argued

Infinity International, Ahmedabad vs. NFAC, Delhi Present Juris. the ITO, Ward-3(3)(1), Ahmedabad

In the result, appeal of the assessee is dismissed

ITA 518/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2016-17

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalinfinity International, Nfac, Delhi Vs. H-611, Titanium City Centre, Present Jurisdiction 100 Ft. Anandnagar Road, Ito, Ward 3(3)(1), Satellite, Ahmedabad-380015 Ahmedabad [Pan: Aaefi 2610 J] (Appellant) .. (Respondent) Appellant By: Shri S.N. Soparkar, Sr. Advocate & Ms. Ukti Shah, Ar Respondent By: Shri Alpesh Parmar, Cit-Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 10.03.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147Section 148Section 153(3)Section 250Section 68

International Vs. ITO Asst. Year : 2016-17 - 3– 5. Aggrieved by the order of the Ld. CIT(A), the assessee is now in appeal before the Tribunal. 6. Before us, the Ld. AR submitted that the reassessment proceedings initiated u/s 147 of the Act are bad in law and liable

Kaidvana Muvada P Dudh Utpadak Sahkari Mandali Limited, Panchmahal vs. The ITO, Ward-1, Godhra

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

ITA 2325/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2019-20

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Mehul K. Patel, AdvocateFor Respondent: Shri C Dharani Nath, Sr. DR
Section 234ASection 250(6)Section 271ASection 69C

application for condonation of delay along with the affidavit filed by the assessee explaining the reasons for the delay in filing the present appeal before the Tribunal. In the affidavit, the Secretary of the assessee society has stated that the impugned order passed by the Commissioner of Income Tax (Appeals

Deputy Commissioner of Income Tax, Circle-3(1)(1), Ahmedabd, Ahmedabad, Gujarat vs. Hemantkumar Rajendrakumar Shah, Ahmedabad, Gujarat

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

ITA 1371/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad10 Mar 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

For Appellant: Shri Akhilendra Pratap Yadaw, CIT. DRFor Respondent: Ms Urvashi Shodhan, AR
Section 143(2)Section 143(3)Section 145(3)Section 68

foregoing, the appeal is partly allowed…” 5. Aggrieved by the order of the Ld. CIT(A), the Revenue is now in appeal before the Tribunal. 6. We have gone through the records and and find that books of account were duly audited, the Ld. CIT(A) held that rejection

M/S. Kamakshi Jute Industries Limited, Kolkata vs. ACIT, Circle 1(1), Kolkata

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

ITA 3151/KOL/2025[2017-2018]Status: DisposedITAT Kolkata10 Mar 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115JSection 143(2)Section 143(3)Section 2(24)(x)Section 250Section 36(1)(va)

dated 10.10.2025. The assessee had sought adjournment but the same was withdrawn and the case was heard. 2. The Assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. For that on the facts and in the circumstances of the case ... accordingly dismissed the appeal of the assessee. 4. Aggrieved with the order of the Ld. Addl/JCIT(A), the Assessee has filed the appeal before the Tribunal. 5. Rival contentions were heard and the submissions made have been examined. It was stated that the due date of deposit

Mission Table Tennis Development Trust, Kolkata vs. The Commissioner of Income Tax (Exmption), Kolkata

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

ITA 1992/KOL/2025[N.A.]Status: DisposedITAT Kolkata10 Mar 2026

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 12ASection 12A(1)(ac)

12AB(1)(b)(ii) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 25.06.2025. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. The order u/s. 12AB ... provisional certificate issued to the assessee was also cancelled. Aggrieved with the order of the Ld. CIT (Exemption), the assessee has filed the appeal before the Tribunal. 5. Rival contentions were heard and the submissions made have been examined. It was stated by the Ld. AR that

M/S. Tamil Nadu Trade Promotion Organisation, Chennai vs. DCIT, Chennai

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

ITA 3351/CHNY/2025[2017-18]Status: DisposedITAT Chennai10 Mar 2026AY 2017-18

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 3351/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Tamil Nadu Trade Promotion The Deputy Commissioner Organization, Vs. Of Income Tax 6 – A/B/C, (Exemptions), Mount Poonamallee Road, Chennai. Nandambakkam, Chennai – 600 089. Pan: Aabct 6725H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri B. Ramakrishnan, Fca ""यथ" क" ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई क" तारीख/Date Of Hearing : 10.03.2026 घोषणा क" तारीख/Date Of Pronouncement : 10.03.2026

For Appellant: Shri B. Ramakrishnan, FCAFor Respondent: Shri M. Rajan, CIT
Section 25Section 250

appellate order passed by the CIT(A) had escaped the attention of the management within the prescribed time limit for filing further appeal before the Tribunal. Immediately upon becoming aware of the impugned order, the assessee approached its counsel, and upon his advice filed the present appeal before the Tribunal ... with a delay of 235 days. On perusal of the reason stated, we find there is sufficient cause for delay in filing this appeal before the Tribunal. Hence, we condone the delay in filing the appeal and proceed to dispose off the appeal on merits. :- 3 -: 3. At the very

Sharayu Synthetics Processors, Bhiwandi vs. DCIT Appeal, Kalyan

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

ITA 7172/MUM/2025[2018-2019]Status: DisposedITAT Mumbai10 Mar 2026AY 2018-2019

Bench: Shri Saktijit Dey & Shri Jagadishassessment Year: 2018-19 Sharayu Synthetics Vs. Dcit Appeal Processors Mohan Plaza Khadakpada Kalyan, Kalyan-Dombivali, H No 1662 Saraswati Maharashtra-421301 Compound, Near Ganesh Society, Bhiwandi, Maharashtra- 421302

Section 143(3)Section 145(3)Section 250Section 44A

Sharayu Synthetics Processors 2. At the outset, it is noticed that there is a delay of 341 days in filing the present appeal before the Tribunal. The assessee has filed an affidavit explaining the reasons for the delay stating that the appellate order was communicated to the email address

Mitesh Suresh Shah, Mumbai vs. ITO International Taxation Ward 4(2)(1), Mumbai

In the result, the appeal filed by the assessee stands partly allowed with no order as to cost

ITA 5593/MUM/2025[2016-17]Status: DisposedITAT Mumbai10 Mar 2026AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarmitesh Suresh Shah Vs. Ito-International Tax 401, 4Th Floor, Blue Heaven, Ward-4(2)(1), Mumbai Nehru Road, Vakola, Kautilya Bhavan, Pipeline, Santacruz (East), Bandra Kurla Complex, Mumbai-400055 Bandra (East), Mumbai- 400051 Pan/Gir No. Auxps9395K (Applicant) (Respondent) Assessee By Ms. Dinkle Hariya, Adv. Revenue By Shri Krishna Kumar (Sr. Dr.) Date Of Hearing 11.02.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 29.03.2022 Passed U/S 144C Of The Income Tax Act, 1961 (‘The Act’), By The Office Of The Income Tax Officer Ward 4(2)(1), Mumbai For The Assessment Year 2016-17. The Following Grounds Are Reproduced Below: “1. The Order Is Bad In Law, Illegal & Without Jurisdiction

Section 144CSection 147Section 68

Bombay High Court, it is clear that liberty was granted to the assessee to challenge the order of the AO by filing an appeal before the Tribunal. The Hon’ble Bombay High Court has also considered the fact that in the earlier assessment year