Section 250 of the Income Tax Act

Income-tax Act, 2025: s.359

Section 250 of the Income-tax Act, 1961 corresponds to section 359 (Procedure in appeal) of the Income-tax Act, 2025.

Read section 359 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 250 is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 of the 26,976 judgments on BharatTax that turn on this section.

Leading authorities on Section 250

Collector, Land Acquisition v. Mst. Katiji
167 ITR 471 · 1987 · Supreme Court
3,926
citing judgments

Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.

CIT v. Vegetable Products Ltd.
88 ITR 192 · 1973 · Supreme Court
2,664
citing judgments

When two equally plausible interpretations of a taxing provision are possible, or when conflicting views exist from non-jurisdictional High Courts, the interpretation that favors the assessee must be adopted.

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

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.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

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.

Goetze (India) Ltd. v. CIT
284 ITR 323 · 2006 · Supreme Court
1,842
citing judgments

An assessee cannot raise a new claim or a claim not made in the original or revised return of income for the first time directly before the Assessing Officer during assessment proceedings.

Fatehraj Singhvi v. UOI
73 Taxmann.com 252 · 2016 · High Court
1,778
citing judgments

Late fees under section 234E are not applicable for periods prior to June 1, 2015, as the amendment to section 200A inserting clause (c) was effective from that date.

Radhasoami Satsang v. CIT
193 ITR 321 · 1992 · Supreme Court
1,695
citing judgments

The principle of consistency applies in tax matters, meaning a fundamental aspect found to be true in one assessment year should not be changed in a subsequent year if the order was not challenged.

CIT v. B.N. Bhattacharya & Another
118 ITR 461 · 1997 · Supreme Court
1,656
citing judgments

Appealing a tax assessment requires more than just filing the appeal; it involves actively pursuing it. The assessee must effectively engage with the appellate process.

Judgments on Section 250

DCIT 19 1 Mumbai, Mumbai vs. Mafatlal Mangilal Kothari, Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

ITA 7094/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 May 2026AY 2019-20

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokar & & & Mafatlal Mangilal The Asst. C.I.T. Kothari Circle 19(1), 904, 9Th Floor, Vs. Room No. 506, 5Th Panchratna, Opera Floor, Piramal House, Mumbai Chamber, Lalbaug, Maharashtra – 400004. Mumbai, Maharashtra- 400012 Pan/Gir No. Agypk9896N (Applicant) (Respondent) & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N Assessee By Mr. Shri Dharan Gandhi Revenue By Shri Umashankar Prasad Cit Dr Date Of Hearing 09.04.2026 Date Of Pronouncement 05.05.2026 आदेश / Order Per Bench These Six Appeals Comprise Four Appeals Filed By The Assessee & Two Appeals Filed By The Revenue, Arising Out Of Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)"]Under Section 250 Of The Income Tax Act, 1961[Hereinafter Referred To As "The Act"], For Assessment Years 2016–17, 2017–18, 2019–20 & 2020–21. Since Common Issues Are Involved In All These Appeals, They Were Heard Together & Are Being Disposed Of By Way Of This Consolidated Order. For The Sake Of Convenience, Assessment Year 2016–17 Is Taken As The Lead Year. Common Facts 2. The Assessee Is An Individual. The Assessments For The Impugned Years Have Been Framed Under Section 147 Of The Actpursuant To Reopening Proceedings Initiated On The Basis Of Information Received From The Investigation Wing.

Section 131Section 131(1)Section 132Section 147Section 148Section 148ASection 151Section 250

DCIT 19 1 Mumbai, Mumbai vs. Mafatlal Mangilal Kothari, Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

ITA 7093/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 May 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokar & & & Mafatlal Mangilal The Asst. C.I.T. Kothari Circle 19(1), 904, 9Th Floor, Vs. Room No. 506, 5Th Panchratna, Opera Floor, Piramal House, Mumbai Chamber, Lalbaug, Maharashtra – 400004. Mumbai, Maharashtra- 400012 Pan/Gir No. Agypk9896N (Applicant) (Respondent) & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N Assessee By Mr. Shri Dharan Gandhi Revenue By Shri Umashankar Prasad Cit Dr Date Of Hearing 09.04.2026 Date Of Pronouncement 05.05.2026 आदेश / Order Per Bench These Six Appeals Comprise Four Appeals Filed By The Assessee & Two Appeals Filed By The Revenue, Arising Out Of Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)"]Under Section 250 Of The Income Tax Act, 1961[Hereinafter Referred To As "The Act"], For Assessment Years 2016–17, 2017–18, 2019–20 & 2020–21. Since Common Issues Are Involved In All These Appeals, They Were Heard Together & Are Being Disposed Of By Way Of This Consolidated Order. For The Sake Of Convenience, Assessment Year 2016–17 Is Taken As The Lead Year. Common Facts 2. The Assessee Is An Individual. The Assessments For The Impugned Years Have Been Framed Under Section 147 Of The Actpursuant To Reopening Proceedings Initiated On The Basis Of Information Received From The Investigation Wing.

Section 131Section 131(1)Section 132Section 147Section 148Section 148ASection 151Section 250

M/S Mafatlal Mangilal Kothari, Mumbai vs. The Asstt. CIT Circle 19(1), Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

ITA 5897/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 May 2026AY 2020-21

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokar & & & Mafatlal Mangilal The Asst. C.I.T. Kothari Circle 19(1), 904, 9Th Floor, Vs. Room No. 506, 5Th Panchratna, Opera Floor, Piramal House, Mumbai Chamber, Lalbaug, Maharashtra – 400004. Mumbai, Maharashtra- 400012 Pan/Gir No. Agypk9896N (Applicant) (Respondent) & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N Assessee By Mr. Shri Dharan Gandhi Revenue By Shri Umashankar Prasad Cit Dr Date Of Hearing 09.04.2026 Date Of Pronouncement 05.05.2026 आदेश / Order Per Bench These Six Appeals Comprise Four Appeals Filed By The Assessee & Two Appeals Filed By The Revenue, Arising Out Of Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)"]Under Section 250 Of The Income Tax Act, 1961[Hereinafter Referred To As "The Act"], For Assessment Years 2016–17, 2017–18, 2019–20 & 2020–21. Since Common Issues Are Involved In All These Appeals, They Were Heard Together & Are Being Disposed Of By Way Of This Consolidated Order. For The Sake Of Convenience, Assessment Year 2016–17 Is Taken As The Lead Year. Common Facts 2. The Assessee Is An Individual. The Assessments For The Impugned Years Have Been Framed Under Section 147 Of The Actpursuant To Reopening Proceedings Initiated On The Basis Of Information Received From The Investigation Wing.

Section 131Section 131(1)Section 132Section 147Section 148Section 148ASection 151Section 250

M/S Mafatlal Mangilal Kothari, Mumbai vs. The ACIT Circle 19 (1), Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

ITA 5896/MUM/2025[2019-20]Status: DisposedITAT Mumbai05 May 2026AY 2019-20

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokar & & & Mafatlal Mangilal The Asst. C.I.T. Kothari Circle 19(1), 904, 9Th Floor, Vs. Room No. 506, 5Th Panchratna, Opera Floor, Piramal House, Mumbai Chamber, Lalbaug, Maharashtra – 400004. Mumbai, Maharashtra- 400012 Pan/Gir No. Agypk9896N (Applicant) (Respondent) & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N Assessee By Mr. Shri Dharan Gandhi Revenue By Shri Umashankar Prasad Cit Dr Date Of Hearing 09.04.2026 Date Of Pronouncement 05.05.2026 आदेश / Order Per Bench These Six Appeals Comprise Four Appeals Filed By The Assessee & Two Appeals Filed By The Revenue, Arising Out Of Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)"]Under Section 250 Of The Income Tax Act, 1961[Hereinafter Referred To As "The Act"], For Assessment Years 2016–17, 2017–18, 2019–20 & 2020–21. Since Common Issues Are Involved In All These Appeals, They Were Heard Together & Are Being Disposed Of By Way Of This Consolidated Order. For The Sake Of Convenience, Assessment Year 2016–17 Is Taken As The Lead Year. Common Facts 2. The Assessee Is An Individual. The Assessments For The Impugned Years Have Been Framed Under Section 147 Of The Actpursuant To Reopening Proceedings Initiated On The Basis Of Information Received From The Investigation Wing.

Section 131Section 131(1)Section 132Section 147Section 148Section 148ASection 151Section 250

M/S Mafatlal Mangilal Kothari, Mumbai vs. The ACIT Circle 19(1), Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

ITA 5895/MUM/2025[2016-17]Status: DisposedITAT Mumbai05 May 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokar & & & Mafatlal Mangilal The Asst. C.I.T. Kothari Circle 19(1), 904, 9Th Floor, Vs. Room No. 506, 5Th Panchratna, Opera Floor, Piramal House, Mumbai Chamber, Lalbaug, Maharashtra – 400004. Mumbai, Maharashtra- 400012 Pan/Gir No. Agypk9896N (Applicant) (Respondent) & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N Assessee By Mr. Shri Dharan Gandhi Revenue By Shri Umashankar Prasad Cit Dr Date Of Hearing 09.04.2026 Date Of Pronouncement 05.05.2026 आदेश / Order Per Bench These Six Appeals Comprise Four Appeals Filed By The Assessee & Two Appeals Filed By The Revenue, Arising Out Of Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)"]Under Section 250 Of The Income Tax Act, 1961[Hereinafter Referred To As "The Act"], For Assessment Years 2016–17, 2017–18, 2019–20 & 2020–21. Since Common Issues Are Involved In All These Appeals, They Were Heard Together & Are Being Disposed Of By Way Of This Consolidated Order. For The Sake Of Convenience, Assessment Year 2016–17 Is Taken As The Lead Year. Common Facts 2. The Assessee Is An Individual. The Assessments For The Impugned Years Have Been Framed Under Section 147 Of The Actpursuant To Reopening Proceedings Initiated On The Basis Of Information Received From The Investigation Wing.

Section 131Section 131(1)Section 132Section 147Section 148Section 148ASection 151Section 250

M/S Mafatlal Mangilal Kothari, Mumbai vs. The ACIT Circle 19(1), Mumbai

In the result, all the appeals filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

ITA 5894/MUM/2025[2017-18]Status: DisposedITAT Mumbai05 May 2026AY 2017-18

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokar & & & Mafatlal Mangilal The Asst. C.I.T. Kothari Circle 19(1), 904, 9Th Floor, Vs. Room No. 506, 5Th Panchratna, Opera Floor, Piramal House, Mumbai Chamber, Lalbaug, Maharashtra – 400004. Mumbai, Maharashtra- 400012 Pan/Gir No. Agypk9896N (Applicant) (Respondent) & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N & Dcit 19 (1), Mafatlal Mangilal 506 Piramal Chambers Kothari Lalbag, Mumbai Vs. 904, 9Th Floor, Maharashtra- 400012 Panchratna, Opera House, Mumbai Maharashtra – 400004. Pan/Gir No. Agypk9896N Assessee By Mr. Shri Dharan Gandhi Revenue By Shri Umashankar Prasad Cit Dr Date Of Hearing 09.04.2026 Date Of Pronouncement 05.05.2026 आदेश / Order Per Bench These Six Appeals Comprise Four Appeals Filed By The Assessee & Two Appeals Filed By The Revenue, Arising Out Of Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)"]Under Section 250 Of The Income Tax Act, 1961[Hereinafter Referred To As "The Act"], For Assessment Years 2016–17, 2017–18, 2019–20 & 2020–21. Since Common Issues Are Involved In All These Appeals, They Were Heard Together & Are Being Disposed Of By Way Of This Consolidated Order. For The Sake Of Convenience, Assessment Year 2016–17 Is Taken As The Lead Year. Common Facts 2. The Assessee Is An Individual. The Assessments For The Impugned Years Have Been Framed Under Section 147 Of The Actpursuant To Reopening Proceedings Initiated On The Basis Of Information Received From The Investigation Wing.

Section 131Section 131(1)Section 132Section 147Section 148Section 148ASection 151Section 250

Azure Power Mars Private Limited, Haryana vs. Del-C, Circle 1(1), Income Tax Officer, Delhi

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

ITTPA 19/DEL/2025[2021-22]Status: DisposedITAT Delhi04 May 2026AY 2021-22

Bench: Shri Ramit Kochar & Shri Anubhav Sharmait(Tp)A No.19/Del/2025 (Assessment Year: 2021-22) Azure Power Mars Private Income-Tax Officer, Limited, Del-C, Circle-1(1), D-Ii, 5Th Floor Southern Park, V. C R Building Saket Place, New Delhi-110017. New Delhi-110002. Pan-Aanca1425H (Appellant) (Respondent) Assessee By Shri Ravi Sharma, Adv. & Ms. Supriya Mehta, Ca Department By Shri S.K. Jadhav, Cit-Dr Date Of Hearing 28.04.2026 Date Of Pronouncement 04.05.2026 Order Per Ramit Kochar, Am: This Appeal In It(Tp)A 19/Del/2025 For Assessment Year: 2021-22 Has Arisen From The Learned Cit(A)’S Appellate Order Dated 17.09.2025 Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Called “The Act”) In Din & Order No: Itba/Nfac/S/250/2025-26/1080810137(1), Which In Turn Has Arisen From The Assessment Order Dated 15.12.2023 Passed By The Learned Assessing Officer, Assessment Unit, Income Tax Department U/S 143(3) R.W.S 144C(3) R.W.S.144B Of The 1961 Act In Din: Itba/Ast/S/143(3)/2023-24/1058810504(1). Brief Facts Of The Case Are That The Assessee Filed Return Of Income On 25Th February, 2. 2022, Showing Total Income At Rs.1,16,69,960/-. The Assessee’S Case Was Selected By Revenue For Framing Scrutiny Assessment Under Cass. During The Course Of Assessment Proceedings, Statutory Notices Were Issued By The Ao To The Assessee From Time To Time

Section 143(2)Section 143(3)Section 144C(1)Section 144C(2)Section 250Section 92C