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

Kalpana Kannangath Kutty, Mumbai vs. Assistant Commissionr of Income Tax Circle-11(1), Mumbai

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

ITA 4896/MUM/2024[2006-07]Status: DisposedITAT Mumbai24 Dec 2024AY 2006-07

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Omkareshwar Chidara, Am Kalpana Kannangath Kutty Assistant Commissioner Of Income Flat No. 4506, 45Th Floor, Tower 4, Tax Circle – 112(1), Mumbai Vs. Crescent Bay, Jerbai Wadia Road, Aayakar Bhawan, M. K. Road, Parel, Mumbai – 400012. Mumbai – 400020. Pan/Gir No. Agipk4160H (Assessee) : (Respondent) Assessee By : Ms. Rutuja Pawar (Virtually Present) A/W. Ms. Sneha More Respondent By : Ms. Sudha Ramachandran, Sr,. Dr Date Of Hearing : 14.11.2024 Date Of Pronouncement : 24.12.2024 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned Commissioner Of Income Tax (Appeals), Delhi (‘Ld. Cit(A)’ For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2006-07. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1) That On The Facts & In The Circumstances Of The Case Of The Appellant & In Law Ld. Nfac Has Erred In Upholding The Infructuous Penalty Of Rs. 5,89,279/- Wrongly Levied For A.Y. 2006-07. 2) That On The Facts & In The Circumstances Of The Case Of The Appellant & In Law Ld. Nfac Has Erred In Considering The Penalty Order Dated 29.03.2012 Passed By Ld. Ao Prior To Passing Of Assessment Order U/S. 143(3) Which Is Dated 19.12.2008. 2 Kalpana Kannangath Kutty

For Appellant: Ms. Rutuja Pawar (Virtually Present) a/w. Ms. Sneha MoreFor Respondent: Ms. Sudha Ramachandran, Sr,. DR
Section 143(1)Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 274Section 275Section 40

Sanjay Kumar Pandey, Patna vs. ITO, 6(2), Patna

The appeal of the assessee is allowed for statistical purposes

ITA 616/PAT/2024[2017-18]Status: DisposedITAT Patna23 Dec 2024AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.616/Pat/2024 Assessment Year: 2017-18 Sanjay Kr. Pandey….………….. ……..……………………....Appellant S. K. Enclave Professor Colony, Near Ojha Lodge, Shivpuri, Patna, Bihar-800023. [Pan: Alupp8547J] Vs. Ito, Ward-6(2), Patna……. ….…….…............................…..…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ajay Kr. Shukla, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 19, 2024 Date Of Pronouncing The Order : December 23, 2024 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 14.06.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 63 Days In Filing The Appeal. The Assessee Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause & Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. No One Has Appeared On Behalf Of The Assessee In Spite Of Serving Notice Of Hearing, Therefore, We Proceed To Decide The Appeal With The Help Of Ld. Dr & Also Considering The Material Available On Record.

Section 143(1)Section 250Section 250(6)Section 44ASection 68

The Begusarai Central Cooprative Bank Ltd, Begusarai vs. ITO, Neac, Delhi

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

ITA 380/PAT/2024[2018-19]Status: HeardITAT Patna23 Dec 2024AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.378 To 380/Pat/2024 Assessment Years: 2016-17 & 2018-19 The Begusarai Central Cooperative Bank Ltd……………………………...……Appellant Mungerigangj, Cooperative Bank Road, Begusara, Bihar-851101. [Pan: Aaajt1701F] Vs. Dc/Ac, Circle-2, Begusarai…………....….…..….........……........……...…..…..Respondent Appearances By: Shri Sanjeev Anwar, Ar, Appeared On Behalf Of The Appellant. Shri Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 19, 2024 Date Of Pronouncing The Order : December 23, 2024 Order Per Sonjoy Sarma: These Three Appeals Have Been Preferred By The Assessee For Different Assessment Years I.E 2016-17 & 2018-19 Against Separate Orders Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In These Appeals Are Common Except Difference In Figures & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. First, We Take Up The Issue In Respect Of Ita No.378/Pat/2024 For Assessment Year 2016-17. Brief Facts Of The Case Are That The Assessee Is A Co-Operative Bank & Filed Its Return Of Income Declaring Total Income Of Rs.1,00,60,860/-. The Case Of The Assessee Was Selected For Scrutiny & The Assessing Officer After Considering The Submission Of The

Section 143(3)Section 250Section 250(6)

The Begusarai Central Cooprative Bank Ltd, Begusarai vs. Dc/Ac Cir-2, Begusarai

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

ITA 379/PAT/2024[2016-17]Status: HeardITAT Patna23 Dec 2024AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.378 To 380/Pat/2024 Assessment Years: 2016-17 & 2018-19 The Begusarai Central Cooperative Bank Ltd……………………………...……Appellant Mungerigangj, Cooperative Bank Road, Begusara, Bihar-851101. [Pan: Aaajt1701F] Vs. Dc/Ac, Circle-2, Begusarai…………....….…..….........……........……...…..…..Respondent Appearances By: Shri Sanjeev Anwar, Ar, Appeared On Behalf Of The Appellant. Shri Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 19, 2024 Date Of Pronouncing The Order : December 23, 2024 Order Per Sonjoy Sarma: These Three Appeals Have Been Preferred By The Assessee For Different Assessment Years I.E 2016-17 & 2018-19 Against Separate Orders Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In These Appeals Are Common Except Difference In Figures & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. First, We Take Up The Issue In Respect Of Ita No.378/Pat/2024 For Assessment Year 2016-17. Brief Facts Of The Case Are That The Assessee Is A Co-Operative Bank & Filed Its Return Of Income Declaring Total Income Of Rs.1,00,60,860/-. The Case Of The Assessee Was Selected For Scrutiny & The Assessing Officer After Considering The Submission Of The

Section 143(3)Section 250Section 250(6)

The Begusarai Central Cooprative Bank Ltd, Begusarai vs. Dc/Ac, Circle-2, Begusarai

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

ITA 378/PAT/2024[2016-17]Status: HeardITAT Patna23 Dec 2024AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.378 To 380/Pat/2024 Assessment Years: 2016-17 & 2018-19 The Begusarai Central Cooperative Bank Ltd……………………………...……Appellant Mungerigangj, Cooperative Bank Road, Begusara, Bihar-851101. [Pan: Aaajt1701F] Vs. Dc/Ac, Circle-2, Begusarai…………....….…..….........……........……...…..…..Respondent Appearances By: Shri Sanjeev Anwar, Ar, Appeared On Behalf Of The Appellant. Shri Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 19, 2024 Date Of Pronouncing The Order : December 23, 2024 Order Per Sonjoy Sarma: These Three Appeals Have Been Preferred By The Assessee For Different Assessment Years I.E 2016-17 & 2018-19 Against Separate Orders Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In These Appeals Are Common Except Difference In Figures & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. First, We Take Up The Issue In Respect Of Ita No.378/Pat/2024 For Assessment Year 2016-17. Brief Facts Of The Case Are That The Assessee Is A Co-Operative Bank & Filed Its Return Of Income Declaring Total Income Of Rs.1,00,60,860/-. The Case Of The Assessee Was Selected For Scrutiny & The Assessing Officer After Considering The Submission Of The

Section 143(3)Section 250Section 250(6)

Manish Kumar, Siwan vs. Assessment Unit Income Tax Department, Delhi

The appeal of the assessee is allowed for statistical purposes

ITA 262/PAT/2024[2018-19]Status: DisposedITAT Patna23 Dec 2024AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.262/Pat/2024 Assessment Year: 2018-19 Manish Kumar………………….……………………………………….…..……Appellant Takkipur, Maharajganj, Siwan, Bihar-841244. [Pan: Djrpk9679G] Vs. Assessment Unit, Income Tax Department ....….........……........……...…..…..Respondent Appearances By: Shri Anjan Biswas, Fca, Appeared On Behalf Of The Appellant. Shri Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2024 Date Of Pronouncing The Order : December 23, 2024 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 02.01.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Engaged In A Business Of Customer Service Point (Csp) Of Sbi Maharajganj Branch & Filed His Return Of Income For The Assessment Year 2018-19. An Information Was Received By The Assessing Officer Indicating A Potential Tax Liability During The Year. He Also Noticed That A Sum Of Rs.1,96,17,279/- Was Received As Commission Income During The Assessment Year. The Assessing Officer Thereafter Reopened The Case Of The Assessee U/S 147 Of The Act By Issuing Notice U/S 148 Of The Act & The Assessee Failed To Response To The Notice. Subsequently, The

Section 142(1)Section 147Section 148Section 250Section 69A

Mahabir Prasad Jain, Gaya vs. ITO Ward 3(1) Gaya, Gaya

The appeal of the assessee is allowed for statistical purposes

ITA 354/PAT/2023[2017-18]Status: HeardITAT Patna23 Dec 2024AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.354/Pat/2023 Assessment Year: 2017-18 Mahabir Prasad Jain………….. ……..……………………....Appellant Tekari Road, Purani Godown, Gaya (Bihar), Bihar- 823001. [Pan: Acbpj8044N] Vs. Ito, Ward-3(1), Gaya……. ….…….…............................…..…..... Respondent Appearances By: Shri Jitendra Kr. Sinha, Advocate, Appeared On Behalf Of The Appellant. Shri Ajay Kr. Shukla, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2024 Date Of Pronouncing The Order : December 23, 2024 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 13.10.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Ld. Ar Submitted That There Is A Delay Of 05 Days In Filing The Instant Appeal. The Assessee Has Submitted An Application For Condonation Of Delay Citing Reasonable Grounds. After Considering The Averments Made In The Application, We Condone The Delay. 3. Brief Facts Of The Care Are That The Assessee Is A Senior Citizen & Engaged In The Wholesale Business Of Salt. The Assessee Did Not File A Return Of Income For The Relevant Assessment Year Due To Severe Health Issues. The Assessing Officer Observed That The Assessee Had Made Cash

Section 144Section 148Section 250Section 69A

Rajeev Ranjan, Naubatpur vs. Assessing Officer, Patna

The appeal of the assessee is allowed for statistical purposes

ITA 348/PAT/2023[2017-2018]Status: DisposedITAT Patna23 Dec 2024AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.348/Pat/2023 Assessment Year: 2017-18 Rajeev Ranjan………………….……………………………………….…..……Appellant C/O Kanhaiya Prasad Sharma, Naubatpur, Gopalpur, Bihar – 801109. [Pan: Anipr8115J] Vs. Ito, Ward-5(1), Patna…………………......….........……........……...…..…..Respondent Appearances By: Shri Abhishek Agrawal, Ca, Appeared On Behalf Of The Appellant. Shri Ajay Kr. Shukla, Jcit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2024 Date Of Pronouncing The Order : December 23, 2024 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 13.10.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed His Return Of Income By Declaring Total Income For The Assessment Year 2017-18 At Rs.3,68,850/-. The Case Of The Assessee Was Selected For Scrutiny Followed By Notices Issued U/S 143(1) & 143(2) Of The Act. However, The Assessee Failed To Comply With The Notices Issued By The Assessing Officer. Accordingly, The Assessing Officer Based On Material Available Passed An Ex Parte Order U/S 144 Of The Act By Making Addition Of Rs.1,05,76,650/- & Added The Same To The Total Income Of The Assessee.

Section 143(1)Section 144Section 250Section 250(6)

Dhaneshwari Devi, Gaya vs. ITO Ward- 3 (1), Gaya

The appeal of the assessee is allowed for statistical purposes

ITA 242/PAT/2023[2017-18]Status: DisposedITAT Patna23 Dec 2024AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.242/Pat/2023 Assessment Year: 2017-18 Dhaneshwari Devi…………….……………………………………….…..……Appellant Manipur, Buniadganj, Gaya (Bihar) – 823003. [Pan: Aanjpd3158J] Vs. Ito, Ward-3(1), Gaya…….............…..….…..….........……........……...…..…..Respondent Appearances By: Shri Jitendra Kr. Sinha, Advocate, Appeared On Behalf Of The Appellant. Shri Ajay Kr. Shukla, Jcit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 19, 2024 Date Of Pronouncing The Order : December 23, 2024 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 25.05.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Time Of Hearing, The Ld. Ar Stated That There Is Delay Of 9 Days In Filing The Instant Appeal. In This Connection, The Assessee Has Filed An Application Stating Reasons For Such Delay In Filing The Appeal Before This Tribunal. We, After Going Through The Application, Find That There Is Reasonable Cause For The Delay. Accordingly, We Condone The Delay Of 9 Days In Filing The Appeal & Proceed To Adjudicate The Issue On Merits Of The Case. 3. Brief Facts Of The Case Are That The Assessee Is An Individual & Engaged In A Business Of Power-Loom & Filed His Return Of Income For

Section 143(2)Section 250Section 69A

Bharat Rai, Muzaffarpur vs. ACIT, Circle-1, Muzaffarpur

The appeals of the assessee are allowed for statistical purposes

ITA 476/PAT/2022[2017-18]Status: DisposedITAT Patna23 Dec 2024AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.475&476/Pat/2022 Assessment Years: 2015-16 & 2017-18 Bharat Rai…………………………………………………..………….……Appellant Prop Sanjeev Construction, Minapur, Muzaffarpur, Bihar – 843128. [Pan: Aiapr8158A] Vs. Acit, Circle-1, Muzaffarpur...….….. ……………….........……...…..…..Respondent Appearances By: Shri N. K. Lal, Fca, Appeared On Behalf Of The Appellant. Shri Ajay Kr. Shukla, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 19, 2024 Date Of Pronouncing The Order : December 23, 2024 Order Per Sonjoy Sarma: The Present Appeals Have Been Preferred By The Assessee Against Separate Orders Both Dated 08.04.2022 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) For Assessment Years 2015- 16 & 2017-18 Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, The Ld. Ar Submitted That There Is A Delay Of 60 Days In Filing Both The Appeals. The Assessee Has Filed Applications For Condonation Of Delay Citing Valid & Proper Reasons. After Considering The Averments Made In The Applications, We Condone The Delay In Both The Appeals.

Section 143(3)Section 250Section 250(6)

Bharat Rai, Muzaffarpur vs. ACIT, Circle-1, Muzaffarpur

The appeals of the assessee are allowed for statistical purposes

ITA 475/PAT/2022[2015-16]Status: DisposedITAT Patna23 Dec 2024AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. Nos.475&476/Pat/2022 Assessment Years: 2015-16 & 2017-18 Bharat Rai…………………………………………………..………….……Appellant Prop Sanjeev Construction, Minapur, Muzaffarpur, Bihar – 843128. [Pan: Aiapr8158A] Vs. Acit, Circle-1, Muzaffarpur...….….. ……………….........……...…..…..Respondent Appearances By: Shri N. K. Lal, Fca, Appeared On Behalf Of The Appellant. Shri Ajay Kr. Shukla, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 19, 2024 Date Of Pronouncing The Order : December 23, 2024 Order Per Sonjoy Sarma: The Present Appeals Have Been Preferred By The Assessee Against Separate Orders Both Dated 08.04.2022 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) For Assessment Years 2015- 16 & 2017-18 Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, The Ld. Ar Submitted That There Is A Delay Of 60 Days In Filing Both The Appeals. The Assessee Has Filed Applications For Condonation Of Delay Citing Valid & Proper Reasons. After Considering The Averments Made In The Applications, We Condone The Delay In Both The Appeals.

Section 143(3)Section 250Section 250(6)