“Section 251(1)(a)”

Section References (mined)Section 251Section 251(1)(a)1,012 judgments

The decision most relied on for Section 251(1)(a) is Jute Corporation of India Ltd. v. CIT (187 ITR 688), cited in 1,372 judgments on BharatTax.

Leading authorities on Section 251(1)(a)

Jute Corporation of India Ltd. v. CIT

187 ITR 688 · 1991 · Supreme Court

1,372

citing judgments

The Commissioner of Income Tax (Appeals) possesses co-terminus powers with the Assessing Officer and can direct the Assessing Officer to perform actions he failed to do, but cannot introduce a new source of income in the assessment. The appellate assessment must be confined to the items of income that were the subject matter of the original assessment.

CIT v. Premkumar Arjundas Luthra (HUF)

297 CTR 614 · 2017 · High Court

659

citing judgments

The Commissioner of Income-tax (Appeals) cannot dismiss an appeal for non-prosecution or default in appearance. Under Section 250(6) of the Income-tax Act, the CIT(A) must decide the appeal on its merits, even in an ex parte proceeding.

CIT v. Shapoorji Pallonji Mistry

44 ITR 891 · 1962 · Supreme Court

278

citing judgments

The Commissioner of Income-tax (Appeals) cannot enhance an assessment by introducing a new source of income or by changing the head of income during appellate proceedings.

Skycell Communications Ltd. v. DCIT

251 ITR 53 · 2001 · High Court

253

citing judgments

Technical services involve human intervention and expertise, not just routine or machine-based operations. Routine customer support and standard facility provision through technology do not constitute technical services under the Act.

CIT v. Sardari Lal & Co.

251 ITR 864 · 2001 · High Court

240

citing judgments

An appellate authority cannot introduce a new source of income that was not considered by the Assessing Officer; taxability of new sources should be addressed through reassessment provisions like Section 147/148 or revision under Section 263.

CIT v. Claris Lifesciences Ltd.

326 ITR 251 · 2010 · High Court

196

citing judgments

If approval from the Department of Scientific and Industrial Research (DSIR) for an in-house R&D centre is granted during the previous year, the assessee is entitled to claim weighted deduction under section 35(2AB) for the entire expenditure incurred during that year.

Smt. Prabhavati S. Shah v. CIT

231 ITR 1 · 1998 · High Court

186

citing judgments

The first appellate authority must admit additional evidence if it is necessary for determining the true state of affairs and preventing undue hardship or a failure of justice, even without a specific request and particularly when the case falls under Rule 46A(1)(c).

Berger Paints India Ltd. v. CIT

266 ITR 99 · 2004 · Supreme Court

181

citing judgments

The Revenue cannot take a conflicting stand from what it had earlier accepted in a previous assessment year without compelling justification. This principle of consistency applies to various issues, including the treatment of customs duty in closing inventory.

Judgments citing Section 251(1)(a)

Sachin Pandurang Alhat, Pune vs. Income Tax Officer, Ward 10(2), Pune

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

ITA 8/PUN/2025[2016-17]Status: DisposedITAT Pune10 Mar 2025AY 2016-17

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.8/Pun/2025 िनधा"रण वष" / Assessment Year: 2016-17 Sachin Pandurang Alhat, V The Income Tax Officer, Flat No.202, Bld No.P6, A S Ward-10(2), Pune. Wing, Gandarwanagari, Pune – 412501. Pan:Ahepa6396E Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil S. Pathak & Mrs. Arrchena Sheety Revenue By Shri Arvind Desai – Addl.Cit(Dr) Date Of Hearing 10/03/2025 Date Of Pronouncement 10/03/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961; Dated 05.11.2024 For Assessment Year 2016-17. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Appellant Has Not Been Duly Represented By His Iip In The Course Of Assessment Proceedings & Have Again Not Been Duly

Section 148Section 250

stating the points for determination and then render a decision on each of the points which arise for consideration with reasons in support. Section 251(1)(a) and (b) of the Act provide that while disposing of appeal the CIT(A) would have the power to confirm, reduce, enhance ... dismiss the appeal on account of non-prosecution of the appeal by the assessee. This is amply clear from the Section 251(1)(a) and (b) and Explanation to Section 251(2) of the Act which requires the CIT(A) to apply his mind to all the issues which arise

Sudha Ramani, Chennai vs. Income Tax Officer, Non Corporate Ward 10(3), Chennai

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

ITA 3352/CHNY/2024[2010-11]Status: DisposedITAT Chennai07 Mar 2025AY 2010-11

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.3352/Chny/2024 िनधा"रण वष"/Assessment Year: 2010-11 Sudha Ramani, Vs. The Income Tax Officer, Flat A3, 862, Siddharth Manor, Non Corporate Ward 10(3), Poonamallee High Road, Kilpauk, Chennai. Chennai 600 010. [Pan:Ahepr9857M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Venkata Raman, C.A. ""थ" की ओर से/Respondent By : Shri A. Sasikumar, Cit सुनवाई की तारीख/ Date Of Hearing : 25.02.2025 घोषणा की तारीख /Date Of Pronouncement : 07.03.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2010-11. 2. The Assessee Raised 3 Grounds Of Appeal, Amongst Which, The Only Issue Emanates For Consideration As To Whether The Ld. Cit(A) Is Justified

For Appellant: Shri R. Venkata Raman, C.AFor Respondent: Shri A. Sasikumar, CIT

Section 147Section 251(1)(a)

file of the Assessing Officer for fresh assessment in view of the amendment brought in by way of insertion of first proviso to section 251(1)(a) of the Act and prayed to dismiss the ground raised by the assessee. 4 I.T.A. No.2380/Chny/24 7. Heard both the parties and perused ... matter to the file of the Assessing Officer in view of the amendment brought in by way of insertion of first proviso to section 251(1)(a) of the Act. We note that the said amendment came into effect from 01.10.2024, wherein, the ld. CIT(A) has power to remand

Subrata Mukherjee, Kolkata vs. DCIT, Cir. 5(1), Kolkata

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

ITA 471/KOL/2024[2011-12]Status: DisposedITAT Kolkata06 Mar 2025AY 2011-12

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 250Section 250(6)

shall state the points for determination, the decision thereon and the reason for the decision. (6A) . . . . . . . . . . . . . . . . . . (7) . . . . . . . . . . . . . . . . . . Powers of the Commissioner (Appeals) "Section 251(1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers — (a) in an appeal against an order of assessment, he may confirm ... stating the points for determination and then render a decision on each of the points which arise for consideration with reasons in support. Section 251(1)(a) and (b) of the Act provide that while disposing of appeal the CIT(A) would have the power to confirm, reduce, enhance

Rishikesh Mercantile Pvt. Ltd., Kolkata vs. ITO, Ward-4(1), Kolkata

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

ITA 2431/KOL/2024[2012-13]Status: DisposedITAT Kolkata06 Mar 2025AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 245Section 250Section 250(4)

thereon and the reason for the decision. I.T.A. No.: 2431/KOL/2024 Assessment Year: 2012-13 Rishikesh Mercantile Pvt. Ltd. … Powers of the Commissioner (Appeals) "Section 251(1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers — (a) in an appeal against an order of assessment ... stating the points for determination and then render a decision on each of the points which arise for consideration with reasons in support. Section 251(1)(a) and (b) of the Act provide that while disposing of appeal the CIT(A) would have the power to confirm, reduce, enhance

Kabbur Poorva Bhag Vividoddhesha Prathamik Grameen Krushi S Sangh Ni, Kabbur vs. Income Tax Officer, Ward - 1, Nipani

The appeal stands allowed for statistical purposes

ITA 304/PAN/2024[2018-19]Status: DisposedITAT Panaji05 Mar 2025AY 2018-19

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 304/Pan/2024 Assessment Year : 2018-19 The Kabbur Purvbhag Prathamik Krushi Pattin Sahakari Sangh Niyamit At Post: Kabbur, Tal.:Chikodi, Dist.:Belgaum. Pan : Aadat9192J . . . . . . . Appellant V/S Income Tax Officer Ward-1, Nippani. . . . . . . . Respondent Appearances Assessee By : None Revenue By : Mr S Manikandan [‘Ld. Dr’] Date Of Conclusive Hearing : 04/03/2025 Date Of Pronouncement : 05/03/2025 Order Per G. D. Padmahshali, Am; The Assessee Is In Appeal Against Din & Order No. Itba/Nfac/S/250/2024-25/1069069880(1) Dt. 25/09/2024 Passed U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereafter] By The National Faceless Appeal Centre, Delhi [‘Ld. Cit(A)/Nfac’ Hereafter] Which In Turn Arisen Out Of Order Of Assessment Dt. 10/03/2021 Passed U/S 143(3) Of The Act By The National Faceless E-Asstt. Centre, Delhi [‘Ld. Ao’ Hereafter] For Assessment Year 2018-19 [‘Ay’ Hereafter].

For Appellant: NoneFor Respondent: Mr S Manikandan [‘Ld. DR’]

Section 143(1)Section 143(2)Section 143(3)Section 250Section 251Section 80P(2)

IN THE INCOME TAX APPELLATE TRIBUNAL, PANAJI BENCH, PANAJI BEFORE HON’BLE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI

The Gokak Taluka Agricultural Produced Co-Op Marketing Society Ltd, Gokak vs. Deputy Commissioner of Income Tax, Circle - 1, Belgaum

ITA 274/PAN/2024[2020-21]Status: DisposedITAT Panaji04 Mar 2025AY 2020-21

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 274/Pan/2024 Assessment Year : 2020-21 The Gokak Taluka Agricultural Produced Co-Op. Marketing Society Ltd. Apmc Yard, Gokak, Dist. Belgaum Pan : Aaajt1462H . . . . . . . Applicant V/S Deputy Commissioner Of Income Tax, Circle-1, Belgaum. . . . . . . . Respondent Appearances Assessee By : Mr S Gadadi [‘Ld. Ar’] Revenue By : Mr S Manikandan [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 03/03/2025 घोषणा की तारीख / Date Of Pronouncement : 04/03/2025 Order Per G. D. Padmahshali; The Captioned Appeal Of The Assessee Impugns Din & Order Itba/Nfac/S/250/2024-25/1065710654(1) Dt. 18/06/2024 Passed By The National Faceless Appeal Centre, Delhi [‘Ld. Nfac’ Hereinafter] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] Which In Turn Arisen Out Of Order Of Assessment Dt. 22/09/2022 Passed U/S 143(3) Of The Act By The National Faceless E-Asstt Centre [‘Ld. Ao’ Hereinafter] Anent To Assessment Year 2020-21 [‘Ay’ Hereinafter].

For Appellant: Mr S Gadadi [‘Ld. AR’]For Respondent: Mr S Manikandan [‘Ld. DR’]

Section 143(3)Section 250Section 251Section 251(1)(a)

IN THE INCOME TAX APPELLATE TRIBUNAL, PANAJI BENCH, PANAJI BEFORE HON’BLE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI

Ranjana Naik Mirsangkar, Begim vs. Income Tax Officer, Ward - 2(1), Panaji

ITA 145/PAN/2024[2015-16]Status: DisposedITAT Panaji04 Mar 2025AY 2015-16

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 145/Pan/2024 Assessment Year : 2015-16 Ranjana Naik Mirsangkar H.No. 614, Walkeshwar Wada, Betim, Bardez, North Goa, Goa Pan : Aldpn9981B . . . . . . . Applicant V/S Income Tax Officer, Ward-2(1), Goa. . . . . . . . Respondent Appearances Assessee By : Mr Rahul Sarda [‘Ld. Ar’] Revenue By : Mr M Satish [‘Ld. Dr’] सुनवाई की तारीख / Date Of Conclusive Hearing : 25/02/2025 घोषणा की तारीख / Date Of Pronouncement : 04/03/2025 Order Per G. D. Padmahshali; The Captioned Appeal Of The Assessee Impugns Din & Order Itba/Nfac/S/250/2024-25/1064227170(1) Dt. 19/04/2024 Passed By The National Faceless Appeal Centre, Delhi [‘Ld. Nfac’ Hereinafter] U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ Hereinafter] Which In Turn Arisen Out Of Order Of Assessment Dt. 16/03/2023 Passed U/S 147 R.W.S. 144 R.W.S. 144B Of The Act By The National Faceless E-Asstt Centre [‘Ld. Ao’ Hereinafter] Anent To Assessment Year 2015-16 [‘Ay’ Hereinafter].

For Appellant: Mr Rahul Sarda [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]

Section 147Section 148Section 250Section 250(6)Section 251(1)(a)

IN THE INCOME TAX APPELLATE TRIBUNAL, PANAJI BENCH, PANAJI BEFORE HON’BLE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI

Oplus Steel and Power Pvt. Ltd.(Formerly Known As Swati Concast and Power Pvt. Ltd.), Kolkata vs. D.C.I.T., Circle - 5(1), Kolkata

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

ITA 2550/KOL/2024[2013-2014]Status: DisposedITAT Kolkata28 Feb 2025AY 2013-2014

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(2)Section 147Section 148Section 250Section 68Section 69C

writing and shall state the points for determination, the decision thereon and the reason for the decision. … Powers of the Commissioner (Appeals) "Section 251(1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers — (a) in an appeal against an order of assessment, he may confirm ... stating the points for determination and then render a decision on each of the points which arise for consideration with reasons in support. Section 251(1)(a) and (b) of the Act provide that while disposing of appeal the CIT(A) would have the power to confirm, reduce, enhance

Alka Kumari, Bengaluru vs. ITO, Ward 4(1), Patna

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

ITA 612/PAT/2024[2015-16]Status: DisposedITAT Patna24 Feb 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250

writing and shall state the points for determination, the decision thereon and the reason for the decision. . . . Powers of the Commissioner (Appeals) "Section 251(1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers — (a) in an appeal against an order of assessment, he may confirm ... stating the points for determination and then render a decision on each of the points which arise for consideration with reasons in support. Section 251(1)(a) and (b) of the Act provide that while disposing of appeal the CIT(A) would have the power to confirm, reduce, enhance

Jitendra Kumar, Arwal vs. Addl/JCIT(A)-2 Delhi, Delhi

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

ITA 394/PAT/2024[2017-18]Status: DisposedITAT Patna24 Feb 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 234BSection 250Section 250(6)Section 270A(2)

decision thereon and the reason for the decision. I.T.A. No.: 394/PAT/2024 Assessment Year: 2017-18 Jitendra Kumar. … Powers of the Commissioner (Appeals) "Section 251(1) In disposing of an appeal, the Commissioner (Appeals) shall have the following powers — (a) in an appeal against an order of assessment, he may confirm ... stating the points for determination and then render a decision on each of the points which arise for consideration with reasons in support. Section 251(1)(a) and (b) of the Act provide that while disposing of appeal the CIT(A) would have the power to confirm, reduce, enhance

DCIT, Middletonton Row vs. Bishnupur Public Education Institute, Bishnupur

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

ITA 1021/KOL/2023[2016-17]Status: DisposedITAT Kolkata24 Feb 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Bishnupur Public Education Institute Dcit 10B, Middleton Row, 5 Th Floor, Gopeswarpalli, Bishnupur, Vs. Kolkata-700071, West Bengal Bankura-722122, West Bengal (Appellant) (Respondent) Pan No. Aabtb4176D Assessee By : S/Shri S.M. Surana & Sunil Surana & Dipak Kumar, Ars Revenue By : Shri Subhendu Datta, Dr Date Of Hearing: 03.02.2025 Date Of Pronouncement : 24.02.2025

For Appellant: S/Shri S.M. Surana &For Respondent: Shri Subhendu Datta, DR

Section 11Section 11(2)Section 12ASection 13(9)Section 139Section 139(1)Section 139(4)

report. But still when the issue came before ld. CIT(A) who also possesses coterminus power with that of A.O and as per section 251(1)(a) of the Act, the ld. CIT(A) in disposing the appeal against order of assessment has the power to confirm, reduce, enhance

Mahanth Kumar Singh, Muzaffarpur vs. ITO, Muzaffarpur

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

ITA 232/PAT/2024[2017-18]Status: DisposedITAT Patna20 Feb 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 147Section 148Section 249Section 250Section 69A

Sachin Kumar Dixit, Farrukhabad vs. Income Tax Officer, Ward-4(2)(2), Farrukhabad

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

ITA 203/AGR/2024[2017-18]Status: DisposedITAT Agra19 Feb 2025AY 2017-18

Bench: : Shri Ramit Kochar & Shri Sudhir Kumarassessment Year: 2017-18

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

entire credits in the bank account for the year under consideration , which is not appropriate. Our attention was drawn to proviso to section 251(1)(a) of the Act which was introduced by Finance Act, 2024 wef 01.10.2024, and it was submitted that now even the ld. CIT(Appeals

Ram Kumar, Supaul vs. ITO, 3(5), Saharsa

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

ITA 464/PAT/2024[2017-18]Status: DisposedITAT Patna19 Feb 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

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

Madhuri Devi, Saharsa vs. ITO Ward- 3 (4), Saharsa

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

ITA 238/PAT/2024[2017-18]Status: DisposedITAT Patna19 Feb 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 143(2)Section 144Section 145(3)Section 148Section 250Section 69A

Pravin Rajaram Thorat, Satara vs. ITO Ward-1, Satara

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

ITA 1457/PUN/2024[2017-18]Status: DisposedITAT Pune18 Feb 2025AY 2017-18

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1457/Pun/2024 िनधा"रण वष" / Assessment Year: 2017-18 Pravin Rajaram Thorat, V The Income Tax Officer, Karve Karad, Satara, S Ward-1, Satara. Maharashtra – 415110. Pan: Afmpt4673F Appellant/ Assessee Respondent / Revenue Assessee By Smt. Deepa Khare – Ar Revenue By Shri Abhishek Meshram–Addl.Cit(Dr) Date Of Hearing 13/02/2025 Date Of Pronouncement 18/02/2025 आदेश/ Order Per Dr. Manish Borad, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] For Assessment Year 2017-18 Dated 27.07.2022 Passed U/Sec.250 Of

Section 246ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)Section 251(2)

Santosh Mohan Patole, Mumbai vs. Income Tax Officer - 34(3)(2), Mumbai

In the result appeal filed by the assessee stands allowed

ITA 5810/MUM/2024[2013-14]Status: DisposedITAT Mumbai18 Feb 2025AY 2013-14

Bench: Smt. Beena Pillai ()

Section 144Section 148Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) I.T.A. No.5810/Mum/2024 Assessment Year: 2013

Ramgiri, Gurgaon vs. ITO, Ward-3(1), Gurgaon

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 4394/DEL/2024[2018-19]Status: DisposedITAT Delhi17 Feb 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 147Section 250(6)Section 251(1)(a)Section 251(2)Section 69

appeal in writing with well-reasoned order on each point of determination arisen for his consideration. It is evident from the perusal of section 251(1)(a), 251(1)(b) and Explanation of section 251(2) of the Act that the CIT(A) is required to apply his/her mind ... issues which arise from the impugned order before him/her, whether or not these issues have been raised by the assessee before him/her. 7. Section 251(1)(a) of the Act provides that while disposing of an appeal against assessment order, the CIT(A) shall have the power to confirm, reduce

Cherrie Gems Private Limited, Roorkee vs. Commissioner of Income Tax(Appeals), NFAC, Delhi

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

ITA 98/DDN/2023[2017-18]Status: DisposedITAT Dehradun12 Feb 2025AY 2017-18

Bench: BEFORESHRI VIKAS AWASTHY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

Section 142(1)Section 144Section 250(6)Section 69A

speaking order on merits on all the points for determination including each ground of appeal. It is evident from the perusal of section 251(1)(a), 251(1)(b) and Explanation of section 251(2) of the Act that the CIT(A) is required to apply his/her mind to Page ... issues arisen from the order before him/her, whether or not these issues have been raised by the assessee before him/her. 7. Section 251(1)(a) of the Act provides that while disposing of an appeal against assessment order, the CIT(A) shall have the power to confirm, reduce, enhance

Madan Mohan Gahtori, Udham Singh Nagar vs. ACIT, U.S.Nagar

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 56/DDN/2023[2014-15]Status: DisposedITAT Dehradun12 Feb 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 131Section 144ASection 153ASection 244ASection 251(1)(a)Section 69ASection 69C

speaking order on merits on all the points for determination including each ground of appeal. It is evident from the perusal of section 251(1)(a), 251(1)(b) and Explanation of section 251(2) of the Act that the CIT(A) is required to apply his/her mind ... issues arisen from the order before him/her, whether or not these issues have been raised by the assessee before him/her. 5. Section 251(1)(a) of the Act provides that while disposing of an appeal against assessment order, the CIT(A) shall have the power to confirm, reduce, enhance