“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)

Suresh Jat, Badnawar vs. The Income-Tax Officer, Dhar

Appeal is allowed for statistical purpose

ITA 693/IND/2025[2016-17]Status: DisposedITAT Indore16 Jan 2026AY 2016-17

Bench: Shri B.M. Biyani & Shri Paresh M Joshisuresh Jat, Ito, बनाम/ C/O S.V. Agrawal & Associate Dhar. Vs. Dadi Dham, 24-25, Joy Building Colony, Old Aplasia, Indore. (Pan: Anopj2666E) (Appellant) (Respondent) Assessee By Shri S.N. Agrawal, Ca Revenue By Shri Anup Singh, Cit-Dr Date Of Hearing 08.01.2026 Date Of Pronouncement 16.01.2026 आदेश/ O R D E R

Section 144(1)Section 147Section 148Section 148ASection 194ASection 194HSection 250Section 253Section 69A

necessarily set aside to the AO u/s 251(1)(a) of the Act. In my considered opinion, this is not correct interpretation of section 251(1)(a). The said provision has simply given power to the CIT(A) to set aside cases to the AO wherein orders have been passed

Anil Kumar Jain, New Delhi vs. Dy. Commissioner of Income Tax, Central Circle-26, Jhandewalan, New Delhi

In the result, the appeal of the assessee is allowed

ITA 475/DEL/2025[2013-14]Status: DisposedITAT Delhi16 Jan 2026AY 2013-14

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(1)Section 143(3)Section 147Section 148Section 151

without alleging any failure on the part of Appellant in disclosing full and truly all primary relevant facts during the remand proceedings under Section 251(1)(a) of the Income Tax Act, 1961. 5.1 On the facts and circumstances of the case, the CIT(A) erred in making enhancement

Hero Fincorp Limited, New Delhi vs. ACIT, Circle 11(1), Delhi, C.R. Building

ITA 2542/DEL/2024[2017-18]Status: DisposedITAT Delhi16 Jan 2026AY 2017-18

Bench: Shri Mahavir Singh, Vice Presdient (), Shri Satbeer Singh Godara & Shri Brajesh Kumar Singhआ.अ.सं/.I.T.A No.2542/Del/2024 निर्धारणवर्ष/Assessment Year:2017-18 Hero Fincop Ltd., 34 Community Centre, Basant Lok, Vasant Vihar, New Delhi-110057 बनाम Vs. Assistant Commissioner Of Income Tax, Circle-11(1) C. R. Building, New Delhi-110002 अपीलार्थी Appellant प्रत्यर्थी/Respondent Pan:Aaach0157J Assessee By Shri Rohit Jain, Adv., Shri Deepesh Jain, Adv. & Shri Himanshu Aggarwal Adv. Revenue By Ms. Pooja Swaroop, Cit(Dr) सुनवाईकीतारीख / Date Of Hearing: 14.01.2026 उद्घोषणाकीतारीख/Pronouncement On 16.01.2026 आदेश /Order Per Brajesh Kumar Singh, Am, The Assessee Is Engaged In The Business Of ‘Hire Purchase Leasing & Finance'. This Appeal Is Filed By The Assessee Against The Order Of National Faceless Appeal Center (Nfac)/(First Appellate Authority Hereinafter Referred As “Faa”), Delhi Dated 27.03.2024 Arising Out Of Assessment Order U/S 143(3) Of The Act Dated 29.12.2019For The Assessment Year 2017-18. 2. The Assessee Has Raised Following Grounds Of Appeal: “Disallowance Of Provision For Collection Charges -Rs. 9,75,00,000/-

Section 143(3)Section 154Section 251(1)Section 56(2)(viib)

ground challenging disallowance of provision for collection charges amounting to Rs.9.75,00,000 as not adjudicated', thereby abdicating the statutory mandate of section 251(1) of the Income tax Act, 1961 ("the Act"). 2. That the NFAC erred on facts and in law in not deleting the disallowance of provision ... 2542/Del/2024 7. We have considered the rival submission and the material available on records. The first appellate authority as per the provisions of section 251(1)(a) of the Act may confirm, reduce enhance or annul the assessment in respect of an appeal against the order of the assessment. Therefore

Balu Vithal Pawale, Pune vs. ITO WD- 2(4), Pune

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

ITA 2869/PUN/2025[2017-18]Status: DisposedITAT Pune14 Jan 2026AY 2017-18

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.2869/Pun/2025 निर्धारण वषा / Assessment Year: 2017-18 Balu Vithal Pawale, V Assessing Officer, Village-Kasarsai, S National Faceless Taluka-Mulsi, Assessment Centre, Dist-Pune – 410506. Delhi Pan:Bfcpp7170L Appellant/ Assessee Respondent /Revenue Assessee By Shri B.S.Rajpurohit Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 08/01/2026 Date Of Pronouncement 14/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18 Dated 16.10.2024 Emanating From The Assessment Order Passed Under Section 147R.W.S 144 Read With Section 144B Of The Act, Dated 27.03.2022. The Assessee Has Raised The Following Grounds Of Appeal :

Section 144Section 144BSection 147rSection 246ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)

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

Hashmat Ishaq Parker, Ratnagiri vs. Income Tax Officer, Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 4071/MUM/2025[2015-16]Status: DisposedITAT Mumbai14 Jan 2026AY 2015-16

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Dharan GandhiFor Respondent: Shri Hemanshu Joshi (SR DR)

Section 144Section 147Section 148Section 148ASection 250Section 251(1)(a)Section 282A

both on legal grounds as well as on merits. The Ld. CIT(A), after passing a speaking order and by exercising powers under section 251(1)(a) of the Act, set aside the impugned assessment order and restored the matter to the file of the Ld. AO, as the assessment ... notice must be both “signed and issued.” It is also noted that the assessment was completed ex parte, and therefore, in terms of section 251(1)(a) of the Act, the Ld. CIT(A) was empowered to set aside the impugned assessment order and restore the matter to the file

Hashmat Ishaq Parar, Ratnagiri vs. Income Tax Officer, Mumbai

ITA 3973/MUM/2025[2018-19]Status: DisposedITAT Mumbai14 Jan 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarι.Τ.Α No.4071/Mum/2025 Α.Υ. 2015-16 Ι.Τ.Α. No.3973/Mum/2025 Α.Υ. 2018-19 Hashmat Ishaq Parker Vs Income Tax Officer 1, Furus, Tal-Khed, District- Ratnagiri, Maharashtra- 415710 Pan : Αχορρ1815Η Appellant Income Tax Office, Ward 17(3)(1), Mumbai-400051 Respondent Assessee By : Shri Dharan Gandhi Respondent By : Shri Hemanshu Joshi (Sr Dr) Date Of Hearing : 08/01/2026 Date Of Pronouncement : 14/01/2026 Order Per Bench: Both The Appeal Was Filed By The Assessee By Challenging The Order Of The Nfac Delhi [For Brevity, ‘Ld.Cit(A)'] Order Passed Under Section 250 Of The Income-Tax Act, 1961 (For Brevity, ‘The Act), Date Of Order 20/12/2024 & 06/12/2024 Related To Assessment Year 2015-16 & 2018-19 Respectively. The Impugned Orders Emanated From The Order Of The Learned Income Tax Officer Ward 1 Ratinagiri (For Brevity, ‘The Ld.Ao') Order Passed U/S 147 R.W.S. 144 Of The Act, Date Of Orders 20/03/2023 & 21/03/2023 For Assessment Years 2015-16 & 2018-19. 2. Since All The Appeals Pertain To The Same Assessee, Involving Similar Issues Arising Out Of A Similar Factual Matrix, These Appeals Were Heard Together As A Matter Of Convenience & Are Being Decided By Way Of This Consolidated Order. With The Consent Of The Parties, The Appeal For The Assessment Year 2015-16 Is Treated As A Lead Case & The Decision Rendered Therein Shall Apply Mutatis Mutandis To Other Appeal For Ay 2018-19 Before Us.

For Appellant: Shri Dharan GandhiFor Respondent: Shri Hemanshu Joshi (SR DR)

Section 144Section 147Section 148Section 148ASection 250Section 251(1)(a)Section 282A

Income Tax Officer, Ward-1(3), Tirupati vs. Polu Venkatasubbaiah, Tirupati

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

ITA 1729/HYD/2025[2015-16]Status: DisposedITAT Hyderabad13 Jan 2026AY 2015-16

Bench: the Ld. CIT(A). During the appellate proceedings, the assessee did not appear and also did 4

Section 142(1)Section 144Section 148Section 250Section 251(1)(a)Section 271(1)(c)Section 69

whereby the matter was set aside to the file of the A.O. in accordance with the proviso to Section 251(1)(a) of the Act with a direction to the A.O. to make a fresh assessment in accordance with the rules and timelines prescribed under Section

Nezone Tubes Limited, Kolkata vs. DCIT, Circle 1(1), Kolkata

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

ITA 180/KOL/2025[2015-16]Status: DisposedITAT Kolkata13 Jan 2026AY 2015-16

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 144BSection 147Section 148ASection 149(1)Section 250Section 251(1)(a)Section 68

both in law and on facts by setting aside the assessment to the Learned Assessing Officer for fresh assessment under the powers of Section 251(1)(a) of the Income Tax Act, 1961, in respect of an order passed under Section 147 read with Section 144B and not under Section

Nezone Tubes Limited, Kolkata vs. DCIT, Circle 1(1), Kolkata

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

ITA 179/KOL/2025[2011-12]Status: DisposedITAT Kolkata13 Jan 2026AY 2011-12

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 144BSection 147Section 148ASection 149(1)Section 250Section 251(1)(a)Section 68

Sundaram Subramanian Rep. by Legal Heir S Sundaram, Pudukkottai vs. ITO, Circle-2(1), Trichy

In the result, both the appeals of the Assessee are partly allowed

ITA 2420/CHNY/2025[2014-15]Status: DisposedITAT Chennai12 Jan 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Shiva Srinivas, C.I.T

Section 147Section 148Section 251Section 68

corrected by the ld.CIT(A)), the ld.AR stated that the same is not permissible under law and the provisions of section 251(1)(a), and even otherwise, the same cannot be undertaken , without bringing to the notice of the assessee. :-6-: ITA. Nos:2419 & 2420/Chny/2025 14. The ld.AR pushed ... erroneous. However, instead of deleting the addition, the Ld.CIT(A) proceeded to sustain the same addition by invoking section 69A, exercising powers under section 251(1)(a)/(1A) of the Act. While it is true that the appellate authority has wide and coterminous powers with that of the Assessing Officer

Sundaram Subramanian, Pudukkottai vs. ITO, Circle-2(1), Trichy

In the result, both the appeals of the Assessee are partly allowed

ITA 2419/CHNY/2025[2013-14]Status: DisposedITAT Chennai12 Jan 2026AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Shiva Srinivas, C.I.T

Section 147Section 148Section 251Section 68

Jagram Tegiram Yadav, Mumbai vs. Ward 41.1.2, Mumbai

ITA 7149/MUM/2025[2019-2020]Status: DisposedITAT Mumbai12 Jan 2026AY 2019-2020

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

Section 147Section 148Section 69C

aranr atiieta aftpeor ara tie Hag FI IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH

Sanjay Narendra Bansal, Mumbai vs. Deputy Commissioner of Income Tax 8(2)(1), Mumbai

ITA 7123/MUM/2025[2014-15]Status: DisposedITAT Mumbai12 Jan 2026AY 2014-15

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

Section 143(3)Section 234ASection 250

आयकर अपीलीय अिधकरण "ाय पीठ मुंबई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH

Mumtaz Ali Mohd, Hyderabad vs. Income Tax Officer, Ward-8(1), Hyderabad

ITA 1260/HYD/2024[2014-15]Status: DisposedITAT Hyderabad09 Jan 2026AY 2014-15

Bench: Shri Manjunatha G. & Shri Ravish Sood(Hybrid Hearing) आ.अपी.सं /Ita No.1260/Hyd/2024 (िनधा"रण वष"/Assessment Year:2014-15) Mumtaz Ali Mohd, Vs. Income Tax Officer, Hyderabad. Ward-8(1), Pan: Abppm6593E Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By: Shri K. Vonoth Kannan, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 06/01/2026 घोषणा की तारीख/Date Of 09/01/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 09/01/2024, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 12/05/2023 For The Assessment Year (Ay) 2014-15. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri K. Vonoth Kannan

Section 147Section 148Section 148ASection 68

आयकर अपीलीय अिधकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad Before Shri Manjunatha G., Accountant

Sangeeta Motilal Shahani, Mumbai vs. ITO 27(3)(1), Vashi Navi Mumbai

ITA 7078/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Jan 2026AY 2013-14

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Jayant Bhatt, ARFor Respondent: Shri Asnkit Tiwari, Sr. AR

Section 143(1)Section 143(3)Section 68

# आयकर अपीलीय अिधकरण Ɋाय पीठ मुंबई मŐ। ### IN THE INCOME TAX APPELLATE TRIBUNAL "SMC" BENCH, MUMBAI ## BEFORE SHRI PAWAN SINGH

Harjeet Kaur, Uttar Pradesh vs. Circle 5(1)(1), G B Nagar, Uttar Pradesh

The appeal is allowed and the

ITA 2731/DEL/2025[2017-18]Status: DisposedITAT Delhi09 Jan 2026AY 2017-18

Bench: Shri Anubhav Sharma & Shri Manish Agarwalharjeet Kaur Vs. Circle 5(1)(1) S-004, F Block, Omax Income Tax Department Queen, Gautam Buddha Gb Nagar Nagar, Uttar Pradesh Uttar Pradesh – 201307 201301 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Azzpk6790P Appellant .. Respondent

For Appellant: Sh. Ravi Pratap Mall, AdvFor Respondent: Ms. Pooja Swaroop, CIT, DR

Section 144Section 68

whatever facts have been asserted by the assessee require verification, therefore, CIT(A) was justified to take recourse to the proviso to Section 251(1)(a) of the Act inserted in the Act w.e.f 01.10.2024. P a g e | 6 Harjeet Kaur (AY: 2017-18) 7. Ld. counsel however, asserts ... assessment order thereby giving fresh lease of life in the hands of Assessing Officer. 12. The powers vested by way of proviso to Section 251(1)(a) of the Act upon Commissioners of Appeals in case of assessment made u/s 144 of the Act has to be justified for reasons

Income Tax Officer, Khanna vs. Rohit Gupta, Khanna

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

ITA 861/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh08 Jan 2026AY 2015-16

Bench: it is finally disposed of.

For Appellant: NoneFor Respondent: Shri Rajat Kumar Kureel, CIT, DR

Section 144Section 147Section 148Section 251(1)(a)Section 69

assessment had been completed ex-parte due to non-compliance on the part of the assessee. Taking note of the proviso to section 251(1)(a) of the Act, inserted with effect from 01.10.2024, the Ld. CIT(A) set aside the assessment and restored the matter to the file ... case was completed under section 147 read with section 144 of the Act due to the assessee's non-compliance. The proviso to section 251(1)(a) of the Act, inserted by the Finance Act, 2024 with effect from 01.10.2024, specifically empowers the Commissioner (Appeals) to set aside an assessment

Sharda Devi Singh, Raipur vs. ITO, Mahasamund

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

ITA 632/RPR/2025[2011-12]Status: DisposedITAT Raipur07 Jan 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 632/Rpr/2025 (िनधा"रण वष" Assessment Year: 2011-12) Sharda Devi Singh, Vs Income Tax Officer, W/O Shri Shailendra Singh, Aayakar Bhawan, K-8, Rajdhani Vihar, Saddu, Mahasamund- 493445, Raipur-492001, C.G. C.G. Pan: Clzps1287D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri R. B. Doshi, Ca राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 06.01.2026 घोषणा की तारीख/Date Of Pronouncement : 07.01.2026

For Appellant: Shri R. B. Doshi, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 144Section 147Section 69

appeal in writing with well-reasoned order on each point of determination arisen for his/her 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

Assistant Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Ritu Dhingra, Shakti Vihar, Haibowal Kalan, Ludhiana

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

ITA 862/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh07 Jan 2026AY 2019-20

Bench: him:- (a) That the assessment order dated 31.03.2023 passed u/s 143(3) r.w.s.153C is bad in law in as much no incriminating material was found suggesting any escapement of income at premises of Sh. Avtar Singh Kochhar. (b) That the assessment order passed is non-est and bad in law in as much the proceedings have not been conducted in the manner prescribed by the Department instructions from time to time which are mandatory for compliance by the Learned Authorities particularly with respect

For Appellant: Shri Ashwani Kumar, C.A and Ms. Deepali Aggarwal, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR

Section 131Section 132Section 143(3)Section 144Section 153CSection 153C(3)Section 153DSection 250Section 251(1)(a)

Learned CIT (Appeal) was not justified to set aside the assessment to the file of the Learned Assessing Officer by invoking provisions of Section 251(1)(a) of the Income Tax Act, 1961 in as much as order passed by the Learned Assessing Officer was an order passed u/s 153C ... Therefore, I set-aside the impugned assessment order to the file of AO for making a fresh assessment by invoking amended provisions of section 251(1)(a) which are reproduced as below: "251. (1) In disposing of an appeal, the [***] [Commissioner (Appeals)] shall have the following powers

Ritu Dhingra, Ludhiana vs. Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

ITA 645/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh07 Jan 2026AY 2019-20

Bench: him:-

For Appellant: Shri Ashwani Kumar, C.A and Ms. Deepali Aggarwal, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR

Section 131Section 132Section 143(3)Section 144Section 153CSection 153C(3)Section 153DSection 250Section 251(1)(a)