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

Naranbhai Kanabhai Mayatra, Gandhidham vs. ACIT/DCIT Circle, Gandhidham

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

ITA 96/RJT/2026[2023-24]Status: DisposedITAT Rajkot28 Aug 2026AY 2023-24

Bench: Dr. Arjun Lal Saini & Shri Sonjoy Sarmaआयकरअपीलसं./Ita No. 96/Rjt/2026 ("नधा"रणवष"/Assessment Year: (2023-24) Naranbhai Kanabhai Mayatra Acit/Dcit Circle, Plot No-342/A Apna Nagar, Income-Tax Office, Plot No. 32, Vs. Gandhidham Gujrat 370201 Sector No. 3, Near Iffco Colony, Gndhidham Gujrat 370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Actpm7786Q (अपीलाथ"/Appellant) (""यथ"/Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Ravinder Sindhu, Ld. Cit Dr Date Of Hearing : 11/08/2026 Date Of Pronouncement : 28/08/2026 Order Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2023-24, Is Directed Against The Order Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Passed By The National Faceless Appeal Centre (Nac) Delhi/Commissioner Of Income-Tax (Appeals) [In Short ‘Nfac/Ld.Cit(A)’], Dated 27.11.2025, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer U/S 144 Read With Section 144B Of The Act, Dated 25.03.2025. 2. At The Outset Itself, The Ld. Counsel For The Assessee Assailed The Impugned Order By Contending That The Assessee Could Not Represent His Case Before Ld. Cit(A) & The Order Being An Ex-Parte Order, Stood Vitiated On Account Of Violation Of Naranbhai Kanabhai Mayatra Principle Of Natural Justice. The Ld. Counsel For The Assessee Contended That In The Interest Of Justice, Another Opportunity To Contest The Appeal Before The Assessing Officer May Be Granted To The Assessee. The Ld. Counsel Submitted That During The Appellant Proceedings, Assessee Submitted Confirmation & Additional Evidences Before The Ld. Cit(A), Which Has Not Been Admitted By Ld. Cit(A) & Assessee Wants To Submit More Additional Evidences Before Assessing Officer.

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Ravinder Sindhu, Ld. CIT DR
Section 144Section 144BSection 250

Shri Khadadhar Juth Seva Sahakari Mandli Ltd, Gondal vs. ITO WD 1(2)(1), Rajkot

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

ITA 942/RJT/2026[2018-19]Status: DisposedITAT Rajkot28 Aug 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Sonjoy Sarmaआयकरअपीलसं./Ita No. 942/Rjt/2026 [ "नधा"रणवष"/Assessment Year: 2018-19 ] Shri Khadadhar Juth Seva Income Tax Officer Ito Wd Sahakari Mandli Ltd, Tal. Vs. 1(2)(1), It-Office, New Aayakar Gondal Dist. Rajkot- Bhawan, Gujarat -360311 Vatiaka, Rajkot, Gujarat-360311 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadts1202P (अपीलाथ"/Appellant) (""यथ"/Respondent) Appellant By : Shri R. K. Doshi, Ld. Ar Respondent By : Shri Ram Tiwari, Ld. Cit (Dr) Date Of Hearing : 30/07/2026 Date Of Pronouncement : 28/08/2026 : Order : Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2018-19, Is Directed Against The Order Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As 'The Act') Passed By The National Faceless Appeal Centre (Nac) Delhi/Commissioner Of Income-Tax (Appeals) [In Short 'Nfac/Ld.Cit(A)'], Dated 29.04.2026, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer U/S 147 R.W.S. 144 Of The Act, Dated 30.03.2023. Ita No.942-Rjt-2026 [ Ay 2018-19 ] Shri Khadadhar Juth Seva Sahakari Mandli Ltd V. Ito

For Appellant: Shri R. K. Doshi, Ld. ARFor Respondent: Shri Ram Tiwari, Ld. CIT (DR)
Section 144Section 147Section 250

Dharmesh Construction, Rajkot vs. The ITO Ward 2(1)(1), Rajkot

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

ITA 838/RJT/2026[2018-19]Status: DisposedITAT Rajkot28 Aug 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Sonjoy Sarmaआयकरअपीलसं./Ita No. 838/Rjt/2026 [ "नधा"रणवष"/Assessment Year: 2018-19 ] Dharmesh Construction, The Ito Ward 2(1)(1), Rajkot, Dharmesh, Sant Kabir Road, Vs. It Office, New Aaykar Bhawan, 19 Bharmaniyapara, Vavdi, Vatiaka, Rajkot, Gujarat-360001 Rajkot, Gujarat-360004 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabfd4598H (अपीलाथ"/Appellant) (""यथ"/Respondent) Appellant By : Ms. Devina Patel, Ld. Ar Respondent By : Shri Ganesh Iyer, Ld. Sr. Dr Date Of Hearing : 12/08/2026 Date Of Pronouncement : 28/08/2026 :: Order :: Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2018-19, Is Directed Against The Order Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As 'The Act') Passed By The National Faceless Appeal Centre (Nac) Delhi/Commissioner Of Income-Tax (Appeals) [In Short 'Nfac/Ld.Cit(A)'], Dated 11.02.2026, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer U/S 143(3) R.W.S. 263 Of The Act, Dated 07.02.2024. 2. The Appeal Filed For Assessment Year 2018-19, Is Barred By Limitation By 28 Days. The Assessee Has Moved A Petition Requesting The Bench To Condone The

For Appellant: Ms. Devina Patel, Ld. ARFor Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Section 143(3)Section 250

Rasikbhai Sojitra, Jamnagar vs. Income Tax Officer, Ward 1 (2), Jamnagar

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

ITA 736/RJT/2026[2019-20]Status: DisposedITAT Rajkot28 Aug 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Sonjoy Sarmaआयकर अपील सं./Ita No. 736/Rjt/2026 [ "नधा"रण वष"/Assessment Year: 2019-20 ] Rasikbhai Sojitra, Income Tax Officer, Main Road, At- Dared, Vs. Ward 1 (2), Jamnagar, Ta-Jamnagar, Dist- Jamnagar- Aaykar Bhavan, Jamnagar, Gujarat-361012 Gujarat-361008 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Cwfps0462M (अपीलाथ"/Appellant) (""यथ"/Respondent) Appellant By : Shri P. V. Kachchdiya, Ld. Ar Respondent By : Shri Ram Tiwari, Ld. Sr. Dr Date Of Hearing : 30/07/2026 Date Of Pronouncement : 28/08/2026 : Order : Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2019-20, Is Directed Against The Order Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Passed By The National Faceless Appeal Centre (Nac) Delhi/Commissioner Of Income-Tax (Appeals) [In Short ‘Nfac/Ld.Cit(A)’], Dated 11.03.2026, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer U/S 147 R.W.S. 144 Of The Act, Dated 20.03.2024. 2. At The Outset, Ld. Counsel For The Assessee Submitted That Assessee Did Not Submit The Entire Documents & Evidences Before The Assessing Officer As Well

For Appellant: Shri P. V. Kachchdiya, Ld. ARFor Respondent: Shri Ram Tiwari, Ld. Sr. DR
Section 147Section 250

Mukeshkumar Pravinchandra Juthani, Rajkot vs. The ITO WD-2, Junagadh

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

ITA 46/RJT/2026[2015-16]Status: DisposedITAT Rajkot28 Aug 2026AY 2015-16

Bench: Dr. Arjun Lal Saini & Shri Sonjoy Sarmaआयकरअपीलसं./Ita No. 46/Rjt/2026 ("नधा"रणवष"/Assessment Year: (2015-16) Mukeshkumar Pravinchandra The Cit, (Appeal) Juthani Nfac, Delhi Vs. “Om Shri Padamlaya”, Nr. The I.T.O. Ward – 2 Trikamrayji Haweli 16 – Jagnath Junagadh Gujrat Plot, Dr. Yagnik Road, Opp. Imperial Hotel, Rajkot Gujrat - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abmpj0103A (अपीलाथ"/Appellant) (""यथ"/Respondent) Appellant By : Ms. Leena Tejura, Ld. Ar Respondent By : Shri Ganesh Iyer, Ld. Sr. Dr Date Of Hearing : 03/08/2026 Date Of Pronouncement : 28/08/2026 Order Per,Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Revenue, Pertaining To Assessment Year (Ay) 2015-16, Is Directed Against The Order Under Section 250 Of The Income- Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Passed By The National Faceless Appeal Centre (Nac) Delhi/Commissioner Of Income-Tax (Appeals) [In Short ‘Nfac/Ld.Cit(A)’], Dated 25.01.2024, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer U/S 144 Of The Act, Dated 06.12.2017. Mukeshkumar Pravinchandra Juthani

For Appellant: Ms. Leena Tejura, Ld. ARFor Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Section 144Section 250Section 253(3)

Shree Ranjitpur Seva Sahkari Mandali Limited, Ranjitpar vs. Income Tax Officer, National Faceless Assessment Center

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

ITA 39/RJT/2026[2018-19]Status: DisposedITAT Rajkot28 Aug 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Sonjoy Sarmaआयकरअपीलसं./Ita No. 38&39/Rjt/2026 ("नधा"रणवष"/Assessment Year: (2018-19) Shree Ranjitpar Seva Saharkari Ito (National Faceless Assessment Center) Ito Wd 1 Dwarka Mandli Limited Vs. Income Tax Office, Tal. Kalyanpur, Dwarka Gujarat 361335 Dwarka Gujarat 361335 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aajas7599G (अपीलाथ"/Appellant) (""यथ"/Respondent) Appellant By : Shri Sikander Halali, Ld. Ar Respondent By : Shri Ganesh Iyer, Ld. Sr. Dr Date Of Hearing : 17/08/2026 Date Of Pronouncement : 28/08/2026 Order Dr. Arjun Lal Saini, Am: Captioned Two Appeals Filed By The Assessee, Pertaining To Assessment Year (Ay) 2018-19, Are Directed Against The Separate Orders Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As 'The Act') Passed By The National Faceless Appeal Centre (Nac) Delhi/Commissioner Of Income-Tax (Appeals) [In Short 'Nfac/Ld.Cit(A)'], Both Dated 25.08.2025, Which In Turn Arise Out Of An Assessment Order Passed By The Assessing Officer U/S 143(3) & A Penalty Order Passed By The Assessing Officer U/S270A Of The Act. 2. When The Matter Was Called For Hearing, The Learned Counsel For The Assessee At The Outset Submitted That Both Appeals Have Been Filed By The Assessee Belatedly

For Appellant: Shri Sikander Halali, Ld. ARFor Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Section 143Section 143(3)Section 250Section 270A

Shree Ranjitpar Seva Saharkari Mandli Limted, at Ranjitpar vs. ITO (National Faceless Assessment Center), Dwarka

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

ITA 38/RJT/2026[2018-19]Status: DisposedITAT Rajkot28 Aug 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Sonjoy Sarmaआयकरअपीलसं./Ita No. 38&39/Rjt/2026 ("नधा"रणवष"/Assessment Year: (2018-19) Shree Ranjitpar Seva Saharkari Ito (National Faceless Assessment Center) Ito Wd 1 Dwarka Mandli Limited Vs. Income Tax Office, Tal. Kalyanpur, Dwarka Gujarat 361335 Dwarka Gujarat 361335 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aajas7599G (अपीलाथ"/Appellant) (""यथ"/Respondent) Appellant By : Shri Sikander Halali, Ld. Ar Respondent By : Shri Ganesh Iyer, Ld. Sr. Dr Date Of Hearing : 17/08/2026 Date Of Pronouncement : 28/08/2026 Order Dr. Arjun Lal Saini, Am: Captioned Two Appeals Filed By The Assessee, Pertaining To Assessment Year (Ay) 2018-19, Are Directed Against The Separate Orders Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As 'The Act') Passed By The National Faceless Appeal Centre (Nac) Delhi/Commissioner Of Income-Tax (Appeals) [In Short 'Nfac/Ld.Cit(A)'], Both Dated 25.08.2025, Which In Turn Arise Out Of An Assessment Order Passed By The Assessing Officer U/S 143(3) & A Penalty Order Passed By The Assessing Officer U/S270A Of The Act. 2. When The Matter Was Called For Hearing, The Learned Counsel For The Assessee At The Outset Submitted That Both Appeals Have Been Filed By The Assessee Belatedly

For Appellant: Shri Sikander Halali, Ld. ARFor Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Section 143Section 143(3)Section 250Section 270A