Tax Judgments & Reference Notes

ITAT · Mumbai · 17 source pages

Shri Swami Narayan Hari Mandir Trust

I.T.A. No. 195/Mum/2026

In the result the appeal filed by the assessee stands allowed.

Read the five-part AKHB brief

Facts of the case

“The present appeal filed by the assessee arises out of the order dated 27/12/2025 passed by the Learned Commissioner of Income Tax (Exemptions) [hereinafter the “Ld.CIT(E)”]. 2. Brief facts of the case are as under:- The assessee is a public charitable trust formed on 7/07/1995 and was granted registration under section 12A of the Act, with effect from 01/04/1998. The said registration continued to r emain in force. Pursuant to the amended provisions of the Act, the assessee filed an application in Form No.10AB on 29/05/2025 before the Ld.CIT(E) seeking renewal of its registration under section 12AB of the Act.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have perused the submissions advanced by both sides in light of records placed before us. 4. The impugned order passed by the Ld. CIT(E), in our considered view, suffers from a fundamental lack of application of mind both on facts and in law. The conclusion that the assessee’s application in Form No. 10AB was “incomplete” is plainly contrary to the record. The assessee had furnished all documents as prescribed under Rule 17A(2), including the trust deed, regist ration certificate, earlier registration under section 12A, and audited financial statements. The Ld. CIT(E) has failed to identify any substantive deficiency and has instead …” (source PDF page 13)

Judicial decision

“In the result the appeal filed by the assessee stands allowed.” (source PDF page 16)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 6 source pages

Neeraj Sinha, HUF

I.T.A. No.: 114/PAT/2025

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

Read the five-part AKHB brief

Facts of the case

“This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals) -NFAC, Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2013-14 dated 27.01.2024, which has been passed against the assessment order u/s 147 r.w.s. 144 r.w.s. 144B of the Act, dated 15.03.2022.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have considered the submissions made, gone through the facts of the case and perused the record and the order of the Ld. CIT(A). We find that at both the stages of assessment order before the Ld. AO as well as before the Ld. CIT(A) in the appeal, proper representation was not made on behalf of the assessee as even the assessment order was” (source PDF page 4)

Judicial decision

“In the result, the appeal filed by the assessee is allowed for statistical purposes.” (source PDF page 5)

Outcome — in favour of

Assessee: procedural/statistical relief only. A remand or statistical allowance does not finally decide the underlying tax merits. Review the operative directions for each ground.

AKHB REVIEW POINT

For agricultural-income claims, reconcile cash deposits with land records, crop/yield evidence, sales records and the HUF or individual’s own bank trail. Prepare those materials for the remand hearing.

ITAT · Patna · 12 source pages

Ganadhipati Construction Pvt. Ltd.

I.T.A. No. 297/PAT/2023

In the result, all the appeals of the Revenue in ITA No. 294, 297 to 299/PAT/2023 are dismissed.

Read the five-part AKHB brief

Facts of the case

“The captioned appeals filed by the Revenue, pertaining to assessment years 2018-19 to 2021 -22 are directed against the orders passed by the Learned Commissioner of Income Tax (Appeals), Patna – 3 (hereinafter referred to as the ‘ld. CIT(A)’) even” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the rival contentions and perused the records placed before us. Revenue’s sole grievance in various grounds of appeal is that ld. CIT (A) erred in allowing deduction u/ s 80IA of the Act for A.Y. 2018 -19 to 2021 -22, by treating the assessee as a developer and not a works contractor. We observe that the assessee did not claim the deduction u/ s 80IA of the Act in his” (source PDF page 5)

Judicial decision

“In the result, all the appeals of the Revenue in ITA No. 294, 297 to 299/PAT/2023 are dismissed.” (source PDF page 12)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

For section 80IA, substantiate developer status with contracts, project responsibilities, financial risk and audit documentation. A contractor’s label alone is insufficient; verify return and deduction requirements for each year.

ITAT · Patna · 4 source pages

Vinayak Builders and Developers Pvt. Ltd.

I.T.A. Nos. 64 & 65/PAT/2023

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

Read the five-part AKHB brief

Facts of the case

“The captioned appeals filed by the Assessee, pertaining to assessment years 2011-12 & 2012-13 are directed against the orders passed by the Learned Commissioner of Income Tax (Appeals), Patna -3 (hereinafter referred to as the ‘ld. CIT(A)’) even dated 30.12.2022 passed u/s 250 of the Income Tax Act, 1961 (‘Act’), which is arising out of the assessment order s passed u/s 153A read with section 144 vide order even dated 28.03.2014. 2. At the outset, the ld. counsel for the assessee submitted that there was no appearance before the ld. AO and b est judgement” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the rival contentions and perused the records available on record. We observe that the assessee is a private limited company engaged in the business of builder and developer. Assessee was subjected to search and seizure action u/s 132 of the Act carried out at Tirupati Homes Pvt. Ltd., group of cases, Patna on 28th April, 2011. Notices u/s 153A of the Act were issued but there was no compliance thereto. Since, no details were furnished before the ld. AO, based upon the available records ld. AO passed the best judgement assessment u/s 144A of the Act making addition for unexplained cash credit at ₹1,22,86,000/- and …” (source PDF page 2)

Judicial decision

“In the result, both the appeals of the assessee are allowed for statistical purposes.” (source PDF page 4)

Outcome — in favour of

Assessee: procedural/statistical relief only. A remand or statistical allowance does not finally decide the underlying tax merits. Review the operative directions for each ground.

AKHB REVIEW POINT

Prepare the evidence and service chronology for the restored proceedings; identify the authority receiving the remand and comply with its hearing directions. The remand does not delete tax on its own.

ITAT · Patna · 7 source pages

Vijaya Singh

ITA No. 519/PAT/2024

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

Read the five-part AKHB brief

Facts of the case

“The present appeal is directed at the instance of assessee against the order of ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 19th June, 2024 passed for Assessment Year 2018-19.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“I have heard both the sides. It was the submission of the ld. Counsel for the assessee that the assessee is having 15 acres of agricultural land and she earned an amount of Rs.39,45,200/- on account of agricultural income in the year under consideration, but the ld. CIT(Appeals) as well as ld. Assessing Officer failed to appreciate the facts given by the assessee and simply they denied and added to the income of the assessee as undisclosed income under section 68 of the Income Tax Act and also taxed as per section 115BBE. Ld. Counsel further submitted that the interest also arbitrarily charged under section 234B for an amount of Rs.11,49,462/-, therefore, he pleaded to set aside the orders passed by the lower authorities. 6. On the other hand, it was the submission of the ld. Departmental …” (source PDF page 5)

Judicial decision

“In the result, the appeal filed by the assessee is partly allowed.” (source PDF page 7)

Outcome — in favour of

Mixed or issue-specific disposition. Read each ground and the operative directions; the result must not be presented as a win on every issue.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 16 source pages

Patna Iron Pvt. Ltd. / Sushil Kumar Kanodia

ITA No .373/PAT/2025

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed.

Read the five-part AKHB brief

Facts of the case

“These appeals of two different assessee’sappeal by the Revenue are against the order of the Commissioner of Income -tax (Appeals), patna-3 (hereinafter referred to as the “Ld. CIT(A)”] dated 31.05.2025& 30.03.2025 for the AY 2020-21 (Cross Appeals) & A.Y. 2017-18. A.Y. 2020-21 ITA No. 332/PAT/2025 2. At the time of hearing, ld. Counsel for the assessee pressed ground nos. 3 and 4, which is extracted as under:- “3. For that the learned CIT-(A) has erred in the facts and circumstances of the case in restricting the addition to Rs 55,12,500/ - by applying the Gross profit 15% by suspiciously treating the figures recorded in the seized material as turnover amounting to Rs …” (source PDF page 2)

Discussion by the Hon’ble Tribunal

“we find that the assessee has raised the above additional ground of appeal challenging the jurisdiction of the of the AO to make addition. In our opinion the issued raised in the additional ground is a purely a legal issue qua which all the facts are available in the appeal folder and no further verification of facts are required from any quarter whatsoever. In our considered view the assessee is at liberty to raise any legal issue before any appellate authority for the first time even when the same has not been raised before the lower authorities. The case of the assessee is squarely coverd by the decisions of the Apex court in the case of i) Jute Corporation of India Ltd. Vs CIT in 187 ITR 688 , ii) National” (source PDF page 14)

Judicial decision

“In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed.” (source PDF page 15)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Source discrepancy: The pronouncement states 26 February 2026 but the closing date reads 26 February 2025. Verify the authenticated copy.

ITAT · Patna · 6 source pages

Jainam Ornament Pvt. Ltd.

ITA No .284/PAT/2025

In the result, the appeal of the assessee is allowed.

Read the five-part AKHB brief

Facts of the case

“This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 08.04.2025 for the AY 2017-18. 2. The only issue raised by the assessee in the various grounds of appeal is against the confirmation of addition is against of ₹1,52,18,034/- by the ld. CIT(A) as made by the ld. AO u/s 68 of the Act by rejecting the books of accounts u/s 145(3) of the Act. 3. The facts in brief are that the assessee company is engaged in the business of sale of jewellery, Gold Article, Silver, Diamond etc. and filed the return of income during the year on 31.10.2017, …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have perused the facts on record and also the submission s made before us by the rival parties and noted that the assessee has duly disclosed the sale s made in the profit and loss account and offered the income to tax. Therefore, if the addition is allowed to be sustained, it would result in double taxation of the same income. Moreover, notice issued to the 13 suppliers were duly responded except two meaning thereby that 11 parties have confirmed to have supplied the materials to the assessee. Therefore, mere fact that the assessee has made huge sales on 08.11.2016, cannot be a ground for making the addition in the hands of the assessee. …” (source PDF page 5)

Judicial decision

“In the result, the appeal of the assessee is allowed.” (source PDF page 6)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 8 source pages

Sita Devi

ITA No. 389/PAT/2025

In the result, appeal of the assessee is allowed.

Read the five-part AKHB brief

Facts of the case

“This is an appeal filed by the assessee against the order passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Addl./Joint Commissioner of Income Tax (Appeals) , 3-Kolkata [hereinafter referred to as “the Ld. CIT(A)] dated 30.08.2024, DIN & order” (source PDF page 1)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

“In the result, appeal of the assessee is allowed.” (source PDF page 7)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Delhi · 12 source pages

Sony India Pvt. Ltd.

ITA Nos. 5416 & 5580/Del/2024

In the result the appeal of the Revenue in 5416/Del/2024 and 5580/Del/2024 are dismissed.

Read the five-part AKHB brief

Facts of the case

“These appeals of the revenue are directed against the order of the ld National Faceless Appeal Centre (NFAC), Delhi dated 27.09.2024 pertaining to AYs 2007-08 and 2008-09. 2. The Revenue has filed a revised grounds of appeal as under: 1. "Whether on the facts and circumstances of the case and in law, the Ld. CIT has erred in entertaining and adjudicating the appeal filed by the assessee against the appeal effect order dated 06/08/2021 passed by the Assessing Officer, which is not an appealable order within the meaning of Section 246A of the Income Tax Act, 1961. 2. "Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in assuming …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the rival submissions and have carefully perused the materials on record. The issue before us for adjudication is the twofold- whether the Order Giving Effect to the ITAT order is appealable u/s 246A and if yes, what is the method of calculation of refund, whether the partial refund issued earlier be first adjusted against the interest component or the principal component of refund of tax.” (source PDF page 7)

Judicial decision

“In the result the appeal of the Revenue in 5416/Del/2024 and 5580/Del/2024 are dismissed.” (source PDF page 11)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 14 source pages

Amar Kasera (HUF)

I.T.A. No.: 179/PAT/2023

In the result, all the captioned appeals of the assessee stand allowed.

Read the five-part AKHB brief

Facts of the case

“The captioned appeals have been preferred by the assessee against the separate orders of even dated 28.02.2023 of the Ld. Commissioner of Income Tax (Appeal), Patna-3 [hereinafter referred to as Ld. ‘CIT(A)’] u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) for Assessment Years (AY) 2011-12, 2013-14 to 2015-16. 2. Since the facts and issue involved in all the captioned appeals are identical, hence, the same are heard together and are being disposed of by this common order. 3. The assessee’s appeal ITA No. 179/Pat/2023 for AY 2011-12 is taken as lead case for the purpose of narration of facts.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the rival contentions and gone through the records. At the outset, the Ld. Counsel for the assessee has submitted that in the earlier assessment proceedings carried out u/s. 153A of the Act, the issue relating to LTCG was specifically examined by the Assessing Officer and the said claim of the assessee was accepted by the Assessing Officer. He in this respect has invited our attention to the copy of assessment order passed u/s.153A/143(3) of the Act dated 29.02.2016 for AY 2011-12 to show that no additions, whatsoever, have been made in the said assessment order by the Assessing Officer on account of claim of LTCG. The Ld. …” (source PDF page 2)

Judicial decision

“In the result, all the captioned appeals of the assessee stand allowed.” (source PDF page 14)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Chennai · 7 source pages

Mangadu Natarajan Balasundharam

ITA No.2414/Chny/2025

In the result, the appeal of the assessee is all owed.

Read the five-part AKHB brief

Facts of the case

“This appeal by the assessee is against the order of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centr e (NFAC), Delhi, (in short "CIT(A)") passed u/s. 250 of the Income Tax A ct, 1961 (in short "the Act") dated 28.07.2025 for Assessment Year (AY) 2016-17. 2. The assessee is an individual and filed the retu rn of income for AY 2016-17 on 14.10.2016 declaring taxable income of R s.10,82,190/-. The A.O received information from DDIT(Investigation) that the assessee has not offered the income from sale of plots co-owned by him along with two others.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the parties, and perused the mater ial available on record. The A.O reopened the assessment for the re ason that the assessee has not offered the income arising from sale of a plot of land during the year under consideration. The assessee filed return in r esponse to notice u/s.148 of the Act wherein the assessee has included the LTCG arising from the sale of land. The AO while completing the assessment u/s.14 8 accepted the income returned by the assessee without making any other a dditions/disallowances. The AO subsequently levied penalty u/s.271(1)(c) st ating that there is a concealment of income towards LTCG not declared …” (source PDF page 4)

Judicial decision

“In the result, the appeal of the assessee is all owed.” (source PDF page 7)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 6 source pages

Shambhu Kumar Singh

ITA No. 34/PAT/2025

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

Read the five-part AKHB brief

Facts of the case

“The present appeal is directed at the instance of assessee against the order of ld. Additional/Joint Commissioner of Income Tax (Appeals)-1, Gurugram dated 27th November 2024 passed for Assessment Year 2016-17. 2. Brief facts of the case are that the assessee is an individual, who filed his return of income on 08.04.2016 declaring total” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“I have heard both the sides and perused the material available on record. It is an admitted fact that the assessee was continuously filing the return of income showing agricultural income in the return of income. It is also an admitted fact that some of the agricultural lands of the assessee are not in his name, but it is not in dispute that the assessee is having agricultural land and doing cultivation. From the record, it is seen that the assessee has agricultural lands as per revenue records in his name 19.80 Bighas 36 Katthas and 19 Dhur, which comes to 13.401 acres of land and the remaining land out of 14 Acres, which is 1/3rd proportionately joint ownership with his mother, father and brother, which comes to 5 Bighas 21.75 Katthas i.ē. (0.272 Acres) in his side. So, as per revenue …” (source PDF page 4)

Judicial decision

“In the result, the appeal of the assessee is partly allowed for statistical purposes.” (source PDF page 5)

Outcome — in favour of

Assessee: procedural/statistical relief only. A remand or statistical allowance does not finally decide the underlying tax merits. Review the operative directions for each ground.

AKHB REVIEW POINT

For agricultural-income claims, reconcile cash deposits with land records, crop/yield evidence, sales records and the HUF or individual’s own bank trail. Prepare those materials for the remand hearing.

ITAT · Visakhapatnam · 33 source pages

Kanaparthy Suryaprakasarao

ITA No.239/Viz/2025

In the result, the Cross Objection filed by the assessee is allowed in terms of our aforesaid observations, while for the appeal filed by the revenue having been rendered as academic in nature, is dismissed.

Read the five-part AKHB brief

Facts of the case

“The captioned appeal filed by the Revenue is directed against the order passed by the Commissioner of Income-Tax (Appeals), National Faceless Appeal Center (NFAC), Delhi, dated 21/02/2025, which in turn arises from the order passed by the Assessing Officer under Section 147 r.w.s 144B of the Income Tax Act, 1961 (for short, “Act”), dated 01/02/2024 for Assessment Year 2018-19. 2. The Revenue has assailed the impugned order on the following grounds of appeal before us: 1. Order of the Ld. Commissioner of Income Tax(Appeals), NFAC is erroneous on facts and law. 2. The Ld.CIT(A), NFAC ought to have called for remand report from the Assessing Officer when the appellant has …” (source PDF page 2)

Discussion by the Hon’ble Tribunal

“We have heard the Ld. Authorized Representatives of both parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncements that have been pressed into service by the Ld. Authorized Representatives of both parties to drive home their respective contentions. 15. As the Ld. AR has assailed the validity of the jurisdiction assumed by the A.O. for issuing notice u/s 148 dated 07.04.2022 without obtaining approval from any of the authorities specified u/s 151 of the Act (as was applicable at the relevant point of time), therefore, we shall first deal with the same. 16. …” (source PDF page 12)

Judicial decision

“In the result, the Cross Objection filed by the assessee is allowed in terms of our aforesaid observations, while for the appeal filed by the revenue having been rendered as academic in nature, is dismissed.” (source PDF page 32)

Outcome — in favour of

Mixed or issue-specific disposition. Read each ground and the operative directions; the result must not be presented as a win on every issue.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Bombay High Court · 48 source pages

Chamber of Tax Consultants / BCAS

Income Tax Appeal No. 247 of 2015

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“the present Petition hinges on whether the absence of an explicit "irrevocability clause" in a trust deed renders a public charitable trust "revocable" in law, thereby justifying the rejection of its registration. 11. At the outset, a plain reading of section 12AB of the Act reveals that the conditions for grant of registratio n are an objective satisfaction on the part of the Principal Commission er regarding (i) the objects of the trust, (ii) the genuineness of its a ctivities, and (iii) compliance with other material laws. The section does not contain any condition that the trust deed must have an explicit c lause stating that it is irrevocable before registration is …” (source PDF page 15)

Discussion by the Hon’ble Court

“We have heard the learned counsel for the parties and have perused the papers and proceedings. The entire contro versy in the present Petition hinges on whether the absence of an explicit "irrevocability clause" in a trust deed renders a public charitable trust "revocable" in law, thereby justifying the rejection of its registration. 11. At the outset, a plain reading of section 12AB of the Act reveals that the conditions for grant of registratio n are an objective satisfaction on the part of the Principal Commission er regarding (i) the objects of the trust, (ii) the genuineness of its a ctivities, and (iii) compliance with other material …” (source PDF page 15)

Judicial decision

“the Writ Petition is also disposed of in terms thereof. Howev er, there shall be no order as to costs. 48. This order will be digitally signed by the Private Se cretary/ Personal Assistant of this Court. All concerned will act on production by fax or email of a digitally signed copy of this order. [FIRDOSH P. POONIWALLA, J.] [B. P. COLABAWALLA, J.] Page 48 of 48 MARCH 09, 2026 S.R.JOSHI ::: Uploaded on - 18/03/2026 ::: Downloaded on - 19/03/2026 23:06:18 :::” (source PDF page 48)

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Delhi · 15 source pages

Meena Swarup

ITA No.2050

In the result, appeal of the assessee is allowed.

Read the five-part AKHB brief

Facts of the case

“The present appeal is filed by assessee against the order dated 14.12.2018 passed by Ld. Commissioner of Income Tax (A)-43, New Delhi [“Ld.CIT(A)”] in Appeal No.197/2016-17 u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment order dated 31.12.2016 passed u/s 143(3) of the Act pertaining to Assessment Year 2014-15. 2. Brief facts of the case are that assessee is an individual and is non-resident and return of income was filed on 31.07.2014 declaring total income of INR 47,320/- with ITO, Ward-22(4), Delhi in terms of the e-filing acknowledgement. The case of the assessee was selected for scrutiny by issue of notice u/s 143(2) of the Act dt. …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“we find that assessee’s case is covered by the judgement of Hon’ble Calcutta High Court in the case of PCIT vs Nopany & Sons (supra) wherein Hon’ble High Court held that notice issued u/s 143(2) by the AO who at that relevant point, had no jurisdiction over the assessee, thus, the notice issued u/s 143(2) of the Act had no jurisdiction. 18. Further, the Hon’ble Supreme Court in the case of ACIT vs Hotel Blue Moon (supra) has held that omission on the part of the AO to issue notice u/s 143(2) cannot be a procedural irregularity and the same is not curable. The Hon’ble Allahabd High Court in the case of CIT vs M.I.Builders (P) Ltd. [2012] 349 ITR 271 (Allahabad) held that the notice issued by non-jurisdictional AO is invalid. 19. In case where the jurisdiction is transferred from AO who is …” (source PDF page 13)

Judicial decision

“In the result, appeal of the assessee is allowed.” (source PDF page 15)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Delhi · 11 source pages

Outsystems Singapore Pte. Ltd.

ITA No.1601/DEL/2025

In the result, appeal of the assessee is allowed.

Read the five-part AKHB brief

Facts of the case

“This appeal by the assessee is directed against the Assessment Order passed u/s. 143(3) r.w.s. 144C(13) of the Income Tax Act,1961 (hereinafter referred to as ‘the Act’) dated 10.01.2025, for Assessment Year 2022-23. 2. The assessee in appeal has raised as many as 13 grounds. The ld. Counsel for the assessee at the outset submitted that he is not pressing ground no. 4 of appeal assailing validity of the assessment order without DIN. In light of the” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the submissions made by rival sides and have examined the orders of authorities below. We have also considered the decisions on which respective sides have placed reliance in support of their arguments. Before proceeding to decide merits of the addition, the legal issue raised by the assessee in ground of appeal no.3 challenging validity of the Final Assessment Order in signing the order manually is taken up first for adjudication. A perusal of the impugned order reveals that the assessment order has been signed manually by the Assessing Officer. The assessment has been made under ‘E -Proceedings’. The Board vide Notification …” (source PDF page 4)

Judicial decision

“In the result, appeal of the assessee is allowed.” (source PDF page 9)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 14 source pages

Faridi Foundation

I.T.A. No.: 223/PAT/2023

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

Read the five-part AKHB brief

Facts of the case

“This appeal filed by the assessee is against the order of the Ld. Commissioner of Income Tax (Exemptions)-Patna [hereinafter referred to as the “Ld. CIT (Exemption) ”] passed in respect of registration u/s 12A(1)(ac)(iii) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for AY 2023-24 dated 26.05.2023. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. That the Ld. CIT(Exemptions) has erred in law and on facts by not following the procedure for registration laid out in section 12AB(1)(b) of the” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have considered the submissions made. The assessee also submitted vide paper book – II page 64, 65 that similar query was raised” (source PDF page 12)

Judicial decision

“In the result, the appeal filed by the assessee is allowed for statistical purposes.” (source PDF page 13)

Outcome — in favour of

Assessee: procedural/statistical relief only. A remand or statistical allowance does not finally decide the underlying tax merits. Review the operative directions for each ground.

AKHB REVIEW POINT

Prepare the evidence and service chronology for the restored proceedings; identify the authority receiving the remand and comply with its hearing directions. The remand does not delete tax on its own.

ITAT · Patna · 8 source pages

Nitesh Kumar

I.T.A. No. 50/PAT/2020

In the result, the appeal of the revenue is dismissed. Order is pronounced in the open court on 9th October, 2024

Read the five-part AKHB brief

Facts of the case

“This is the appeal preferred by the revenue against the order of the Ld. Ld. Commissioner of Income Tax (Appeal)-3, Patna (hereinafter referred to as the Ld. CIT(A)”] dated 19.03.2020 for the AY 2017-18. 2. The only issue raised by the revenue in the various grounds of appeal is against the deletion of addition of Rs. 1,05,58,500/- by the Ld. CIT(A) as made by the AO u/s 69A of the Act on account of unexplained money.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the rival contentions and perused the material on record. The undisputed facts are that Shri Nitesh Kumar, proprietor of Hari Om Textiles was intercepted by RPF post, ECR, Danapur, Patna on 13.11.2016 along with three other persons namely Shri Santosh Kumar Saw, s/o Shri Shiv Kumar Saw, Smt. Malti Devi, W/o Shri Santosh Kumar Saw and Smt. Soni Kumari w/o Shri Vijay Kumar with money amounting to Rs. 1,05,58,500/-. Thereafter the team of income tax requisitioned the cash along with the documents and warrant of requisition u/s 132A of the Act dated 16.11.2017 was executed which are available at page 7 to 71 in the revenue’s paper …” (source PDF page 7)

Judicial decision

“In the result, the appeal of the revenue is dismissed.” (source PDF page 8)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Supreme Court · 6 source pages

Madras Bar Association / ICAI

WRIT PETITION (C) NO. 1018 OF 2021

25-year experience/practice requirement declared invalid and unconstitutional in the supplementary order.

Read the five-part AKHB brief

Facts of the case

This supplementary Supreme Court order concerns eligibility of Chartered Accountants for appointment as Accountant/Technical Members of the ITAT and adds paragraphs to the earlier Madras Bar Association judgment. (source PDF page 1; AI-assisted summary)

Discussion by the Hon’ble Court

“We see no difficulty in applying the same analogy to Chartered Accountants, who are to be appointed as Accountant/Technical Members in the ITAT.” (source PDF page 2)

Judicial decision

“We, therefore, hold that the provision which requires a Chartered Accountant to have minimum experience/practice of 25 years for becoming eligible for appointment as Accountant/Technical Member is also invalid and unconstitutional.” (source PDF page 2)

Outcome — in favour of

Petitioners, on the stated eligibility issue. This is tribunal appointment litigation, not a decision on a taxpayer’s assessment.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Source discrepancy: The supplied PDF contains the supplementary order dated 20 November 2025, not the complete earlier judgment. Read the judgment dated 19 November 2025 separately.

Bombay High Court · 26 source pages

Global Hospitality Licensing SARL

WRIT PETITION NO. 1611 OF 2024

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“the present petition can be disposed of on a limited issue – namely, whether the assessment proceedings stand abated, thereby rendering the penalty proceedings unsustainable. The core issue for determination is whether, in the absence of an order passed by Respondent No.1 pursuant to the order of the CIT(A) within the period of limitation specified in Section 153 of the IT Act, the return of income filed by the Petitioner attains finality. If so, it must follow that the assessment proceedings stand abated and, consequently, all proceedings arising therefrom become infructuous. In such circumstances, the penalty order cannot be sustained in law. 24. The Petitioner has …” (source PDF page 14)

Discussion by the Hon’ble Court

“We have carefully considered the rival submissions. There is no dispute about the proposition that there is no inherent right of appeal. It is to be specifically conferred by the statute providing for an appeal. But as stated by the Supreme Court in CIT v. Ashoka Engg. Co. [1992] 194 ITR 645, it is an equally well- settled proposition or law that, if there is a provision conferring a right of appeal, it should be read in a reasonable, practical and liberal manner. We are, therefore, to construe the provisions of section 246 in the light of this well-settled legal position. So far as the first submission is concerned which relates to the …” (source PDF page 20)

Judicial decision

“the Writ Petition is also disposed of in terms thereof. However, there shall be no order as to costs. 37. This order will be digitally signed by the Private Secretary/ Personal Assistant of this Court. All concerned will act on production by fax or email of a digitally signed copy of this order. [FIRDOSH P. POONIWALLA, J.] [B. P. COLABAWALLA, J.] Page 26 of 26 JUNE 22, 2026 Darshan Patil 2026:BHC-OS:14043-DB” (source PDF page 26)

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 8 source pages

Munni Rai

I.T.A. No. 269/Pat/2018

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

Read the five-part AKHB brief

Facts of the case

“The present appeal emanates from order u/s 250 of the Income Tax Act, 1961 (hereafter ‘the Act’), passed by the Ld. Commissioner of Income Tax (Appeals) -2, Patna [hereafter ‘the Ld. CIT(A)]. The impugned order dated 06.08.2018 has been passed in respect o f Ld. AO’s order dated 25.02.2016 (u/s 143(3) r.w.s 254 of the Act. 1.1 This particular case has a unique set of facts which deserve to be enumerated briefly as under: (a) Order u/s 143(3) of the Act dated 30.07.2010 was passed after estimating business income at 7% of gross receipts. The assessee preferred an appeal against this order.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have carefully perused the documents on record and have heard the rival arguments at length. It is seen that the impugned order dated 06.08.2018 mentions the details of impugned order before the Ld. CIT(A) as under: “Instituted on 27/03/2016 from the order of DCIT/ACIT, Circle-4, Patna dated 25.02.2016 Appeal No. CIT(A), Patna-2/10611/2015- 16) Status/Deductor Category Resident Status Resident Nature of Business Others Section under which the order appealed against was passed 143(3) r.ws. 254 Date of Order under which the order appealed against was passed 25/02/2016 Income Assessed (In Rs.) 38967770 Tax/Penalty/Fine/Interest Demanded (in Rs.) 12821900 Date of Hearings(s) 26/03/2018 Present for the appellant Shri S.C. Sannigrahi, CA & AR of the appellant Present for the Department None” …” (source PDF page 6)

Judicial decision

“In result, the appeal filed by Revenue is allowed for statistical purposes.” (source PDF page 7)

Outcome — in favour of

Revenue: procedural/statistical relief only. A remand or statistical allowance does not finally decide the underlying tax merits. Review the operative directions for each ground.

AKHB REVIEW POINT

Prepare the evidence and service chronology for the restored proceedings; identify the authority receiving the remand and comply with its hearing directions. The remand does not delete tax on its own.

ITAT · Patna · 5 source pages

Bihar State Power Generation Company Ltd.

I.T.A. Nos.: 102 to 106/PAT/2023

In the result, all the appeals of the assessee stand allowed.

Read the five-part AKHB brief

Facts of the case

“The captioned appeals have been preferred by the assessee against the separate orders of even date 23.01.2023 of the Ld. Commissioner of Income Tax (Appeal), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ld. ‘CIT (A)’] u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) for Assessment Years (AY) 2013-14 to 2017-18. 2. Since identical issue is involved in all these appeals, hence, these appeals have been heard together, and are being disposed of by this common order for the sake of convenience. 3. The sole issue involved in these appeals is as to whether the assessee is to be treated as assessee in default u/s. …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard rival contentions and gone through the records. A perusal of the impugned order of the Ld. CIT(A) would reveal that there is no dispute to the factual position that BSEB had awarded contract to BHEL for design, engineering, manufacturing, supply of land and plant and equipment for expansion project at Barauni Thermal Power Station at Begusarai, Bihar. The prices for the material as well as the services were mutually settled. Both the parts of the contract i.e. supply of material as well as the cost of services were separate and segregated. However, the Ld. CIT(A) noted that though there were two separate contracts i.e. one …” (source PDF page 3)

Judicial decision

“In the result, all the appeals of the assessee stand allowed.” (source PDF page 5)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 3 source pages

Muzaffarpur Central Co-operative Bank Ltd.

I.T.A. No.280/Pat/2023

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“The present appeal has been preferred by the assessee against the order dated 31.08.2023 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 a cooperative society and engaged in banking business. For the assessment year 2016-17, the assessee filed its return of income on 15.10.2016 by showing a total income of Rs.65,05,270/-. The case of the assessee was selected for limited scrutiny in terms of guidelines issued by the CBDT vide instruction no.5/2007. Accordingly, notices u/s 143(2) and 142(1) of the Act were issued to …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 2 source pages

Manish Kumar

I.T.A. No.: 448/PAT/2024

In the result, appeal of the assessee is treated as partly allowed.

Read the five-part AKHB brief

Facts of the case

“The captioned appeal has been preferred by the assessee against the order dated 18.04.2024 of the Ld. Commissioner of Income Tax (Appeal), Addl/JCIT(A), Jodhpur [hereinafter referred to as ld. ‘CIT (A)’] u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) for Assessment Year (AY) 2016-17. 2. The sole issue involved in this appeal is relating to the net profit rate on the undisclosed business receipts of the assessee. 3. Admittedly, the assessee did not disclose the receipt of Rs.1,05,10,500/- in the return of income. The Assessing Officer (AO) applied the net profit rate @ 12% on the said undisclosed receipts. However, the case” (source PDF page 1)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

“In the result, appeal of the assessee is treated as partly allowed.” (source PDF page 2)

Outcome — in favour of

Mixed or issue-specific disposition. Read each ground and the operative directions; the result must not be presented as a win on every issue.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 7 source pages

Deo Mangal Memorial Trust

I.T.A. No. 65/Pat/2020

In the result, these appeals filed by the Revenue are allowed for statistical purposes.

Read the five-part AKHB brief

Facts of the case

“the appeals is hereby condoned and these three matters are admitted for adjudication. 1.1 This is a batch of three appeals having additions made on same issue for all the three years under consideration. Accordingly, these three matters are being disposed of by a single order. For the sake of convenience, the appeal for AY 2013-14 (ITA No. 65/Pat/2020) is being taken as the lead case. In this case, it is seen that it is an old pending matter which for some reason has been allowed to linger on. It is also seen that ever since the hearing on 16.10.2023 none have appeared from the side of the petitioner, being the assessee. In any case, it is decided to no t keep this …” (source PDF page 2)

Discussion by the Hon’ble Tribunal

“We have carefully considered the submission of Ld. DR and also perused the contents of paper books and carefully gone through the orders of authorities below. A plain reading of section 2(15) of the Act would reveal that in case a charitable organization is carrying out the activities pertaining to relief of the poor; education; yoga, medical relief; preservation of environment, and preservatio n of monuments or place or objects of artistic or historic interest; then the proviso will not be applicable as it is triggered only when the residual limb of the definition of charitable purpose being “any other object of general public utility” is …” (source PDF page 5)

Judicial decision

“In the result, these appeals filed by the Revenue are allowed for statistical purposes.” (source PDF page 6)

Outcome — in favour of

Revenue: procedural/statistical relief only. A remand or statistical allowance does not finally decide the underlying tax merits. Review the operative directions for each ground.

AKHB REVIEW POINT

Prepare the evidence and service chronology for the restored proceedings; identify the authority receiving the remand and comply with its hearing directions. The remand does not delete tax on its own.

ITAT · Patna · 14 source pages

Dolly Ghosh

ITA No. 182/PAT/2022

In the result, the appeal of the assessee is allowed.

Read the five-part AKHB brief

Facts of the case

“Brief facts of the case are that a search and seizure operation was conducted upon the premises of the assessee on 6th September, 2018. According to the Revenue, during the course of search, it revealed that assessee had raised loan from M/s. Shrijan Mahila Vikash Sahyog Samiti Limited. She has repaid the loan in cash and she has received certain amount in cash. Therefore, the ld. Assessing Officer has reopened the assessment. The copy of the reasons for reopening of assessment are placed on record at page no. 44 of the paper book, which reads as under:-” (source PDF page 2)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

“In the result, the appeal of the assessee is allowed.” (source PDF page 14)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Delhi · 26 source pages

Vintage Distillers Ltd.

IT A No s.6435 to 6440 /Del /20 25 (ASSESSMENT YEARS 2019

In the final result, all the six appeals filed by the Assessee for AY 2019-20 to AY 2024 -25 in ITA Nos. 6435/Del/2025 to 6440/Del/2025 are allowed and both the appeals filed by the Revenue for AY 2021-22 and AY 2022 -23 in ITA …

Read the five-part AKHB brief

Facts of the case

“these appeals are related to one assessee and having common issues in all the years, therefore they are taken together and decided by a common order. The details of the appeals are tabulated as under:” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have carefully considered the rival submissions and perused the record. It is undisputed that search u/s 132 was conducted on 24.11.2022, relevant to A.Y. 2023 -24. Thus, A.Y. 2022 -23 is one of the three preceding years under Explanati on 2(iv) to section 148. The Explanation reads that if a search is initiated, "the Assessing Officer shall be deemed to have” (source PDF page 21)

Judicial decision

“In the final result, all the six appeals filed by the Assessee for AY 2019-20 to AY 2024 -25 in ITA Nos. 6435/Del/2025 to 6440/Del/2025 are allowed and both the appeals filed by the Revenue for AY 2021-22 and AY 2022 -23 in ITA Nos.7701/Del/2025 and 7704/Del/2025 respectively, are dismissed.” (source PDF page 26)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 8 source pages

Pancham Singh

ITA No.462/Pat/2025

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

Read the five-part AKHB brief

Facts of the case

“This appeal filed by the assessee is directed against the order dated 29.08.2025 of the NFAC, Delhi [‘CIT(A)’] passed under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”). 2. Brief facts of the case are that the appellant is an individual who had not filed his return of income for the A.Y. 2014-15. The Assessing Officer was having information that the appellant had entered into a LDA with M/s Sehra Real Estate Pvt Ltd. on 27/08/2013 for the development of his immovable property situated at Mauja Rukanpura, Thana No. 5, Circle Danapur, Patna, measuring approximately 7,405.2 sq. ft. Under the agreement, the assessee transferred development …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have considered the submissions of the counsels of the respective parties and perused the materials on record. We find that the assessee entered into a registered agreement for development of his ancestral land on 27-08-2013 for the construction of residential building/ apartment on the said land. On perusal of JDA, we find that nature of deed is "Development Agreement" and it clearly postulates that it is not the sale deed in which the land owner has relinquished his ownership. The land owner is continued to be the owner of the property throughout the development of the property and there is no transfer of ownership to the developer …” (source PDF page 5)

Judicial decision

“In the result, the appeal filed by the assessee is allowed. Kolkata, the 16th March, 2026.” (source PDF page 8)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Kolkata · 6 source pages

Arabinda Paul

ITA No .946/KOL/202 3 (

In the result, the appeal of the assessee is allowed.

Read the five-part AKHB brief

Facts of the case

“This is an appeal preferred by the assessee against the order of the Pr. Commissioner of Income Tax, Kolkata -5 (hereinafter referred to as the “Ld. PCIT”] dated 28.02.2022 for the AY 2017-18. 02. The only issue raised by the assessee in the various grounds of appeal is against the invalid exercise of jurisdiction u/s 263 of the Income -tax Act, 1961 (the Act) by the ld. PCIT, thereby rendering the order passed u/s 263 of the Act as ab initio void and ex -facie, nullity in the eyes of law. 03. The facts in brief are that the return of income was filed by the assessee on 06.11.2017, declaring total income of ₹4,87,850/ -.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“we find that in this case the assessment was framed u/s 143(3) of the Act, after the case of the assessee was selected for limited scrutiny by examining that all cash deposits into the bank during the instant financial year. The copy of the notice issued u/s 143(2) of the Act is available at page no.61 of the Paper Book which states that the case was selected for a limited scrutiny. Therefore, once the case of the assessee is so selected for limited scrutiny and scope is not exp anded by converting the same into complete scrutiny then the ld. AO has to confine himself to the scope of the scrutiny. The ld. AO has righty framed the assessment by examining the cash deposits during the year after calling for the necessary details/ evidences from the assessee, which were duly furnished and …” (source PDF page 4)

Judicial decision

“In the result, the appeal of the assessee is allowed.” (source PDF page 5)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Ahmedabad · 9 source pages

True Sparrow Systems Pvt. Ltd.

I.T.A. No. 1682/Ahd/2025

In the result, appeal filed by the assessee is allowed. This Order

Read the five-part AKHB brief

Facts of the case

“The present appeal has been filed by the Assessee against the order of the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (hereinafter referred to as “NFAC”), Delhi (hereinafter referred to as “CIT(A)”) dated 26.06.2025 passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2021-22.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“Having heard the rival contentions of both the parties, we find no merit in the order passed by the Ld. CIT(A). Undeniably,” (source PDF page 7)

Judicial decision

“In the result, appeal filed by the assessee is allowed. This” (source PDF page 9)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 11 source pages

Bihar State Educational Infrastructure Development Corporation

I.T.A. No.: 344/PAT/2018

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

Read the five-part AKHB brief

Facts of the case

“This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals) -I, Patna [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 (6) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2012-13 dated 09.07.2018,” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have considered the matter. The assessee is developing infrastructure for edu cation institution and orders u/s 264 of the Act have been passed for AY 2016 -17, AY 2018-19 and AY 2020-21 on the basis of which consequential orders have been passed by the Ld. AO. Hence, since the facts are similar in AY 2012-13 as submitted, we deem it appropriate to set aside the orders of the Ld. CIT(A) as well as the Ld. AO and remit the matter to the Ld. AO for framing the assessment order de novo after considering the orders u/s 264 of the Act passed by the Ld. CIT (Exemption) in the aforesaid three assessment years. Since res judicata is not …” (source PDF page 10)

Judicial decision

“In the result, the appeal filed by the assessee is allowed for statistical purposes.” (source PDF page 10)

Outcome — in favour of

Assessee: procedural/statistical relief only. A remand or statistical allowance does not finally decide the underlying tax merits. Review the operative directions for each ground.

AKHB REVIEW POINT

Prepare the evidence and service chronology for the restored proceedings; identify the authority receiving the remand and comply with its hearing directions. The remand does not delete tax on its own.

ITAT · Patna · 7 source pages

Pradeep Kumar Patel

I.T.A. No.: 361/PAT/2024

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

Read the five-part AKHB brief

Facts of the case

“This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals) -NFAC, Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for AY 2017-18 dated 21.09.2023, which has been passed against the penalty order u/s 271B of the Act, dated 21.01.2022.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have considered the submissions made . Section 273B specifies that notwithstanding anything contained in the provisions of sections mentioned therein including section 271B, no penalty shall be imposable on the person or the assessee, as the case may be, for any failure referred to in the said provisions if he proves that there was a reasonable cause for the said failure. The assessee belongs to a remote area where the facilities of a consultant may not be readily available. It is stated that the assessment was made for the first-time u/s 144 of the Act and prior to that the assessee was not aware about the applicability of Income-tax …” (source PDF page 6)

Judicial decision

“In the result, the appeal filed by the assessee is allowed.” (source PDF page 7)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Chennai · 10 source pages

Riaz Ali

ITA No. 790 /202 5 (धििाारणवर्ा /

In the result, appeal filed by the assessee is allowed in terms of our above order.

Read the five-part AKHB brief

Facts of the case

“This appeal by the assessee is arising out of the final assessment order dated 06.01.2025, passed by the Income Tax officer, Intl Taxn Ward 2(1) CH E, Chennai for the assessment year 20 18-19 u/s.147 r.w.s. 144C (13) of the Income Tax Act, 1961 (hereinafter the ‘Act’) in pursuant to the directions of the Dispute Resolution Panel-2, Bengaluru dated 26.12.2024.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard admission of legal issue and found substance in the submissions of the Ld. Counsel for the assessee and hence, we admit the legal issue/jurisdictional ground in view of the decision of the Hon’ble Supreme Court in the case of NTPC v. CIT reported in [1998] 229 ITR 383 (SC). 4. We also note that apart from the additional ground, the assessee has also raised other legal grounds as under: (a) Without an order of transfer u/s.127 of the Act , the assessment order is void ab-initio; (b) Notice u/s 148 of the Act issued by non -jurisdictional assessing officer; (c) Exemption u/s 54 of the Act should be allowed when investment is made …” (source PDF page 2)

Judicial decision

“In the result, appeal filed by the assessee is allowed in terms of our above order.” (source PDF page 10)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Jaipur · 19 source pages

Dependra Singh

ITA. Nos. 247 to 251/JPR/2024

In the result, the appeals of the assessee in ITA. No. 247 to 251/JPR/2024 are allowed.

Read the five-part AKHB brief

Facts of the case

“these appeals aris e from a common set of facts and identical legal issues, the se appeals are heard together and are disposed of by this consolidated order. 2.1 The assessee has raised the following grounds o f appeal vide ITA No. 247/JPR/2024 for A.Y 2013-14 as under:- “1. In the facts and circumstances of the case and in law, ld. CIT(A) has erred in, confirming the action of the ld. AO in as suming jurisdiction in the case of the assessee under Section 153C and pas sing order therein, not in accordance with the provision of la w. The action of the ld. CIT(A) is illegal, unjustified, arbitrary and a gainst the facts of the case. Relief may please be granted by quashing …” (source PDF page 2)

Discussion by the Hon’ble Tribunal

“We have carefully considered the prayer for admi ssion of additional ground. Since it is legal in nature, and all the necessary” (source PDF page 7)

Judicial decision

“In the result, the appeals of the assessee in ITA. No. 247 to 251/JPR/2024 are allowed.” (source PDF page 19)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Delhi · 31 source pages

Shilpi Sardana

ITA No.1425/Del/2024

In the result, appeal of the assessee is partly allowed as indicated above.

Read the five-part AKHB brief

Facts of the case

“This appeal is filed by the Assessee against the o rder of the Ld. Commissioner of Income Tax (Appeals)-NFAC, Delh i dated 29.01.2024 for the AY 2021-22. The assessee in her appeal raised the following grounds:” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“we hold that the assessment framed by the Assessing Officer u/s 143(3) dated 30.12.2019 pursuant to the notice issued u/s 143(2) dated 21.08.2018 which was not in the prescribed format a s notified by the CBDT, is bad in law and void ab initio and the same is hereby” (source PDF page 25)

Judicial decision

“In the result, appeal of the assessee is partly allowed as indicated above.” (source PDF page 26)

Outcome — in favour of

Mixed or issue-specific disposition. Read each ground and the operative directions; the result must not be presented as a win on every issue.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Delhi · 2 source pages

Komal Kumar

ITA No. 7482/Del/2025

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“This assessee’s appeal for Assessment Year 2020-21 arises against the Assessing Officer’s DIN & order No. ITBA/AST/S/147/2024-25/1074540022(1) dated 16.03.2025, in proceedings u/s 147 r.w.s. 144B of the Income Tax Act, 1961 (in short “the Act”). 2. Heard both the parties at length. Case file perused. 3. It transpires during the course of hearing that there arises the first and foremost legal issue of validity of the impugned reopening itself as the learned assessing authority had set into motion the impugned proceedings against the assessee regarding the sole reason of total cash deposits of Rs.2,62,30,808/- whereas his assessment framed on” (source PDF page 1)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 7 source pages

Sarvodaya Samaj Kalyan Sansthan

ITA No.: 563/PAT/2024

In the result, the appeal of the assessee is allowed.

Read the five-part AKHB brief

Facts of the case

“This appeal filed by the assessee is against the order of the ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2018-19 dated 25.06.2024. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. For that the order passed by learned Commission of Income-tax (Appeals) confirming the order passed by CPC, Bengaluru is bad in law as well as on facts. 2. For that the Ld. CIT (Appeals) has further grossly erred in confirming the finding of learned A.O. of treating the appellant trust as AOP for charging tax at …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the Ld. DR. Before us, the assessee had also filed a paper book containing the written submission. It is stated that the appellant-assessee being an Institution solely existing for educational purpose within the meaning of section 10(23C)(iiiad) of the Income Tax Act and is registered under the Societies Act, 1960. The assessee is running an ITI College in the remotest area of Jamui District of Bihar and imparting education to poor students. The primary objective of the assessee-Society is not profit-motive, rather the objective of the assessee-Society is to serve the Society by way of charity as defined in section 2(15) of the …” (source PDF page 5)

Judicial decision

“In the result, the appeal of the assessee is allowed.” (source PDF page 6)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Delhi · 3 source pages

Darshan Lal Makhija

ITA No.4006/Del/2025

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“This assessee’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2024-25/1067634910(1), dated 14.08.2024 involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. Assessee by Sh. Sankalp Malik, Adv. Department by Sh. Manish Gupta, Sr. DR Date of hearing 24.12.2025 Date of pronouncement 24.12.2025” (source PDF page 1)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Source discrepancy: The source gives different pronouncement and closing dates (24 and 30 December 2025). Verify the authenticated copy.

Supreme Court · 19 source pages

DCIT v. Gandhibag Sahakari Bank Ltd.

Special Leave to Appeal(C) No(s). 18917/2024

Revenue’s special leave petition dismissed; underlying High Court judgment is supplied separately in the same PDF.

Read the five-part AKHB brief

Facts of the case

The Revenue sought special leave against the Bombay High Court’s judgment dated 25 September 2023 in W.P. 3177/2022. The supplied PDF contains the Supreme Court record followed by the High Court judgment. (source PDF page 1; AI-assisted summary)

Discussion by the Hon’ble Court

“We are not inclined to interfere with the impugned judgment and order of the High Court; hence, the special leave petition is dismissed.” (source PDF page 1)

Judicial decision

“We are not inclined to interfere with the impugned judgment and order of the High Court; hence, the special leave petition is dismissed.” (source PDF page 1)

Outcome — in favour of

Assessee, in the limited sense that the Revenue’s SLP was dismissed. The Supreme Court record contains no separate reasoning on the tax merits.

AKHB REVIEW POINT

This is a short dismissal of special leave. Read the underlying High Court judgment before identifying its ratio; dismissal of an SLP alone does not reproduce or independently reason through that ratio.

Source discrepancy: Composite source: Supreme Court record dated 3 September 2025 on PDF page 1; underlying Bombay High Court judgment follows. Do not attribute the High Court’s reasoning to the Supreme Court.

ITAT · Chennai · 10 source pages

Kandasamy Selvaraj

ITA No.1852/Chny/2025

In the result, appeal filed by the assessee is allowed in terms of our above order.

Read the five-part AKHB brief

Facts of the case

“The captioned appeal filed by the assessee is dire cted against order of the Ld. Commissioner of Income Tax (Appeal), Che nnai-19 [‘CIT(A)’ in short] dated 23.12.2024 for Assessment Year 2020-21. 2. At the outset, the Ld.AR of the assessee brough t to our notice that the appeal has been filed belatedly by ‘119’ days a nd assessee has filed an affidavit explaining the cause for the delay. H aving gone through the” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the rival submissions perused the appeal papers and case law cited by the assessee. We find that the CB DT issued a Notification dated 29.03.2022 formulating “the e-as sessment of income assessment Scheme, 2022”. The Scheme provides that (a) the assessment/re-assessment are re-computation u/s.147 of the Act and (b) issuance of notice u/s.148 of the Act shall be thro ugh automated allocation, in accordance with risk management stra tegy formulated by the Board as referred u/s.148 of the Act for issuan ce of notice and in a faceless manner to the extent providing in Section 144B of the Act with reference to making …” (source PDF page 3)

Judicial decision

“In the result, appeal filed by the assessee is allowed in terms of our above order.” (source PDF page 9)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Andhra Pradesh High Court · 13 source pages

Andhra Pradesh reassessment writ batch

WRIT PETITION Nos: 14681/2023

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

This brief does not reproduce a factual narrative. Read the complete order for the parties, procedural background and disputed issues.

Discussion by the Hon’ble Court

“we hold that the impugned notices and orders which have been issued by the Jurisdictional Assessing Officer, or outside the faceless mechanism as provided under the provisions of Section 144 (b) read with Section 151 A and the “E-Assessment Scheme of Income E scaping Assessment Scheme, 2022” notified by the Government of India on 29.03.2022 under Section 151 A, is bad and illegal. It” (source PDF page 11)

Judicial decision

“Accordingly, these Writ Petitions are allowed. (i) Consequently, the impugned notices/orders issued under Section s 148-A(b), 148-A(d) and 148 of the Income Tax Act, 1961 , in all these Writ Petitions, are hereby set-aside. (ii) The consequential orders, if any, shall stand set-aside. 9. There shall be no order as to costs. As a sequel, miscellaneous petitions pending, if any, shall stand closed. __________________________ JUSTICE BATTU DEVANAND __________________________________ JUSTICE A.HARI HARANADHA SARMA Note: - Registry to issue C.C. …” (source PDF page 12)

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Telangana High Court · 11 source pages

Sudhakar Reddy Mettu

ITA No.231/Hyd/2024

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“The instant appeal under Section 260A of the Income Tax Act, 1961 (for short the ‘Act’) has been preferred by the appellant challenging the order passed by the Income Tax Appellate Tribunal, Hyderabad ‘A’ Bench, Hyderabad, (for short the ‘ITAT’) in ITA No.231/Hyd/2024, decided on 29.05.2024.” (source PDF page 1)

Discussion by the Hon’ble Court

“We have perused the orders and heard the rival contentions. There is no dispute that on July 28, 2008, the builder gave an allotment letter to the assessee which clearly mentions that Rs. 7.70 crores for villa No. 75 stood paid by the assesses. The sal e of shares giving rise to the capital gains was on July 20, 2007. Maybe it is true that the agreement for construction entered by the assessee with the builder gave an outer date, which went beyond the three-year period from the date of sale of the shares . However, the assessee had done what all it could do for acquiring the villa by paying the whole of the price on July 28, 2007 itself. …” (source PDF page 8)

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Source discrepancy: The filename mentions section 54F, but the source concerns section 54. Use the order, not its filename.

ITAT · Ahmedabad · 5 source pages

Ansh Organisers Private Limited

ITA No.257/AHD/2026

In result appeal of the assessee is allowed.

Read the five-part AKHB brief

Facts of the case

“The assessee has filed its return of income in response to the notice issued u/s. 148 of the Act on 14.06.2024. The AO thereafter, issued notice u/s. 143(2) of the Act on 03.09.2024 and the assessee has duly submitted its response on 22.01.2024 in response to the notice issued u/s. 143(2) of the Act. Thereafter, the AO has issued various notices u/s. 142(1) of the Act, and the assessee has duly submitted its responses before the AO from time to time for verification. The AO, after considering the submissions made by the assessee, has accepted the returned income and passed the assessment order u/s. 147 r.w.s 1448 of the Act on 03.02.2025 without any addition. However, …” (source PDF page 3)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

“In result appeal of the assessee is allowed.” (source PDF page 5)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 10 source pages

Kishori Capital Markets Pvt. Ltd.

I.T.A. No.: 249/PAT/2023

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

Read the five-part AKHB brief

Facts of the case

“The instant appeal filed by the assessee pertaining to the Assessment Year (in short ‘AY’) 2015-16 is directed against the order passed u/s 250 of the Income Tax Act, 1961 (in short the ‘Act’) by ld. Commissioner of Income - tax (Appeal)-NFAC, Delhi [in short ld. ‘CIT(A)’] dated 06.07.2023 arising out of the assessment order framed u/s 143(3) of the Act dated 27.12.2017. 1.1. The brief facts of the case of the appellant are that the assessee is a NBFC company registered with RBI and is carrying mainly the business of” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“we have perused the record and find the following facts which are admitted facts. a) Assessment order was passed on 27.12.2017 b) Notice u/s 148 of the Act for the AY 2015 -16 was issued on 31.03.2021 by the office of the ITO, Ward-2(1), Patna that is after four years. 2.2. Now, we have gone through the judgments cited by the assessee in this context which are as follows: a) Kolkata ITAT - Rungta Irrigation Ltd vs ACIT - ITA no. 1224/Kol/2019 - 06.09.2019 b) Supreme Court - ACIT vs CEAT Ltd - 449 ITR 171 -10.10.2022 c) Calcutta High Court - Calcutta Club Ltd vs ITO - WP No. 719 of 2014 - 14.02.2020 d) Gujarat High Court - Hynoup Food & Oil …” (source PDF page 3)

Judicial decision

“In the result, the appeal filed by the assessee is allowed.” (source PDF page 9)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Allahabad High Court · 6 source pages

Dinesh Jain

WRIT TAX No. - 2021

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“Present petition has been filed to challenge the re-assessment proceedings initiated against the petitioner for the Assessment Year 2016-17, vide notice dated 06.06.2024. 3. Dehors the other merits, it has been strenuously urged that the said notice was wholly barred by limitation. Strong reliance has been placed on the decision of the Supreme Court in Union of India and Others Vs. Rajeev Bansal (and other appeals), (2024) 469 ITR 46 . The aforesaid decision is the last pronouncement on the issue. Relevant to the submissions advanced here, we may usefully extract the contents of” (source PDF page 1)

Discussion by the Hon’ble Court

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

“Accordingly, the writ petition is allowed. The re-assessment notice dated 06.06.2024 is quashed. (Indrajeet Shukla,J.) (Saumitra Dayal Singh,J.) December 18, 2025 Faraz” (source PDF page 6)

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Pune · 17 source pages

Maharashtra State Board of Secondary & Higher Secondary Education

ITA No.825/PUN/2025

In the result, the appeal filed by the Revenue and the Cross Objection filed by the assessee are dismissed.

Read the five-part AKHB brief

Facts of the case

“This appeal filed by the Revenue is directed against the order dated 31.01.2025 of the Ld. Addl / J CIT(A)-2, Gurugram relating to assessment year 2022-23. The assessee has filed the Cross Obje ctions vide CO No.1 9/PUN/2025 against the appeal filed by the Revenue. For the sake of convenience, the appeal” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the rival arguments made by both the sides, perused the orders of the CPC / Assessing Officer and the Ld. Addl / JCIT(A) and the paper book filed by both the sides . We have also considered th e various decisions cited before us. We find the assessee in the instant case instead of claiming the deduction u/s 10(23C)(iv) made wrong claim u/s 10(46) of the Act which was denied by the CPC in the intimation u/s 143(1) of the Act. We find in appeal the” (source PDF page 8)

Judicial decision

“In the result, the appeal filed by the Revenue and the Cross Objection filed by the assessee are dismissed.” (source PDF page 16)

Outcome — in favour of

Mixed or issue-specific disposition. Read each ground and the operative directions; the result must not be presented as a win on every issue.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Mumbai · 29 source pages

Manju Diamonds Pvt. Ltd.

ITA No. 2766/MUM/2025

In the result, the appeal of the Revenue is allowed for statistical purposes whereas the application under Rule 27 of /07/2025.

Read the five-part AKHB brief

Facts of the case

“This appeal by the Revenue is directed against the order dated 14.02.2025 passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as "Ld. CIT(A)"], for the Assessment Year 2017–18. The Revenue has impugned the findings of the Ld. CIT(A) on several grounds, principally revolving around the deletion of an addition of ₹75,50,000/- made under Section 68 of the Income-tax Act, 1961” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard rival submissions on the issue of the admission of the grounds raised in Application filed under Rule 27 of the Rules. We find that the legal ground raised in Rule 27 were raised before the Ld. CIT(A) but the Ld. CIT(A) though has discussed the issue of validity of the reassessment u/s 147 of the Act in favour of th assessee but no specific finding has been given in respect of ground No. 1 raised in application under Rule 27 of the ITAT Rules settled that a legal plea going to the root of the matter, and which affects the very jurisdiction of the assessing entertained at any stage of the proceedings. The objection as to the …” (source PDF page 4)

Judicial decision

“In the result, the appeal of the Revenue is allowed for statistical purposes whereas the application under Rule 27 of /07/2025.” (source PDF page 29)

Outcome — in favour of

Revenue: procedural/statistical relief only. A remand or statistical allowance does not finally decide the underlying tax merits. Review the operative directions for each ground.

AKHB REVIEW POINT

Prepare the evidence and service chronology for the restored proceedings; identify the authority receiving the remand and comply with its hearing directions. The remand does not delete tax on its own.

ITAT · Patna · 7 source pages

Ganesh Ram Dokania

I.T.A. No. 263/PAT/2023

In the result, the appeal of the assessee is allowed on legal issue. Order is pronounced in the open court on 15th October, 2024

Read the five-part AKHB brief

Facts of the case

“This is the appeal preferred by the assessee against the order of the Ld. Ld. Commissioner of Income Tax (Appeal)-NFAC, Delhi (hereinafter referred to as the Ld. CIT(A)”] dated 03.07.2023 for the AY 2012-13. 2. At the time of hearing, the assessee has pressed only the legal issue which is against the order of Ld. CIT(A) confirming the action of AO in initiating the” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“we find that the AO has re-opened the assessment absolutely without application of mind and without making any further enquiries on the information received from the investigation wing. In our view the re- opening has been made just on borrowed satisfaction of ADIT which cannot be a basis of re-opening of assessment u/s 147 of the Act. Therefore , we quash the re-opening of assessment u/s 147 of the as well as the assessment framed pursuant thereto. 9. In the result, the appeal of the assessee is allowed on legal issue. Order is pronounced in the open court on 15th October, 2024 Sd/- Sd/- (Pradip Kumar Choubey /Ĥदȣप कुमार चौबे) (Rajesh Kumar/ राजेश कुमार) Judicial Member/ÛयाǓयक सदèय Accountant Member/लेखा सदèय Dated: 15th October, 2024 SM, Sr. PS Copy of the order forwarded to: 1. …” (source PDF page 7)

Judicial decision

“In the result, the appeal of the assessee is allowed on legal issue.” (source PDF page 7)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 6 source pages

Mohamad Israil Cold Storages Pvt. Ltd.

I.T.A. No.198/Pat/2024

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“The present appeal has been preferred by the revenue against the order dated 23.11.2023 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 filed his return of income for the assessment year 2017-18 by declaring total income of Rs.15,87,600/-. The case of the assessee was selected for complete scrutiny for examination of cash deposits made during the period of demonetization. Accordingly, notices u/s 142(1) and 143(2) of the Act were issued and the assessee responded by submitting his ITR, computation of income, audit …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

“Accordingly, the order of the ld. CIT(A) is upheld and the appeal of the revenue is dismissed. 7. In terms of the above, the appeal of the revenue is dismissed. Kolkata, the 17th January, 2025.” (source PDF page 5)

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 4 source pages

Jivachh Yadav

I.T.A. No.338/Pat/2024

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“The present appeal has been preferred by the assessee against the order dated 28.09.2023 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 Registry has informed that there is a delay of 116 days in filing the present appeal. The ld. AR of the assessee filed an application for condonation of delay stating reasons for such delay. After considering the application, we find reasonable cause for such delay. We, therefore, condone the delay in filing the appeal and adjudicate the appeal on merits of the case. 3. Brief facts of the care are that the …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 3 source pages

Nehal Ahmed

I.T.A. No.365/Pat/2024

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“The present appeal has been preferred by the assessee against the order dated 01.03.2024 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 care are that the assessee is an individual and earned income from civil contract. The assessee filed his return of income for the assessment year 2016-17 by declaring an income of Rs.10,58,610/-. The assessee initially had filed return of income u/s 139(9) of the Act and subsequently revised it declaring the same income. The assessee disclosed income from contractual receipt amounting to Rs.92,51,630/- and …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 6 source pages

Upendra Shukla

ITA Nos. 315, 316, 317/PAT/2023

In the result, all the appeals of the assessee are allowed.

Read the five-part AKHB brief

Facts of the case

“brief facts, we would like to observe that the ld. 1st Appellate Authority has dismissed all the appeals for want of prosecution. Therefore, we cannot make reference of any material mainly from the order of ld. CIT(Appeals). The ld. Counsel for the assessee has filed a detailed written submission, which is common to all the three assessments. In this written submission, he has compiled the details in tabulation proforma, which depicts the nature of dispute. We would like to take note of those details, which read as under:- SI. No. Particulars Assessment years 2015-16 2016-17 2017-18 i. Gross professional fees received from Mentors Eduserve. 2475000 2700000 2700000 ii. …” (source PDF page 2)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

“In the result, all the appeals of the assessee are allowed.” (source PDF page 6)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 50 source pages

Gandhipati Construction Private Limited

ITA Nos. 356 to 360/PAT/2024

In the result, all the appeals of the assessee bearing ITA Nos. 356,357,358, 359 & 360/PAT/2024 are allowed.

Read the five-part AKHB brief

Facts of the case

“These appeals are preferred by the assessee against the orders of ld. Principal Commissioner of Income Tax” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the rival contentions and gone through the material placed before us. In the instant appeal, assessee’s grievance is that Ld. Pr. CIT erred in carrying out revisionary proceedings by assuming jurisdiction u/s. 263 of the Act and that the Ld. Pr. CIT erred in holding that the assessment orders framed u/s. 153A r.w.s. 143(3) of the Act is erroneous and prejudicial to the interest of revenue and that the impugned order deserves to be quashed as the approval granted u/s. 153D of the Act has not been revised. As Section 263 of the Act has a direct bearing on the controversy, therefore, it is pertinent to take note of this section. …” (source PDF page 15)

Judicial decision

“In the result, all the appeals of the assessee bearing ITA Nos. 356,357,358, 359 & 360/PAT/2024 are allowed.” (source PDF page 49)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Madras High Court · 31 source pages

Harigovind / G. Ravindran HUF

W.P.Nos.23014 of 2023

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

This brief does not reproduce a factual narrative. Read the complete order for the parties, procedural background and disputed issues.

Discussion by the Hon’ble Court

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

“Consequently, the connected miscellaneous petitions are also closed. 28.10.2025 Speaking/Non-speaking order Index : Yes / No Neutral Citation : Yes / No nsa To 1. Assistant Commissioner Of Income Tax Non-corporate, Circle 3(1), Chennai-600 034. 2. Assistant Commissioner Of Income Tax Central Circle 2(3) Chennai, 1st Floor Investigation Building, 46, M G Road, Chennai-34. 30/31 https://www.mhc.tn.gov.in/judis ( Uploaded on: 30/10/2025 06:51:40 pm )” (source PDF page 30)

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Kolkata · 7 source pages

Ashok Kumar Agarwal (HUF)

ITA No . 1/KOL/2025

In the result, the appeal of the assessee is allowed.

Read the five-part AKHB brief

Facts of the case

“This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 20.11.2024 for the AY 2017-18. 02. The assessee has challenged the assessment framed by the ld. AO on the ground that no notice u/s 143(2) of the Act has been issued by the jurisdictional Assessing Officer. Besides, the assessee has challenged the assessment on the ground that the notice u/s 143(2) of the Act was not in conformity with the instruction issued by CBDT instruction No.1/2011 (F. No. 187/12/2010-IT(A-1), Dated 31.01.2011.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“we find that the notice issued u/s 143(2) dated 9th August, 2017 was not in any of the formats as provided in the CBDT instruction F.No.225/157/2017/ITA -II dated 23.06.2017. We have e xamined the notice, copy of which is available at page no.1 of the Paper Book and find that the same is not as per the format of CBDT Instruction F.No. 225/157/2017/ITA-II dated 23.06.2017 as stated above. In our opinion, the instruction issued by the CBDT are mandatory and binding on the Income tax authorities failing which the proceedings would be rendered as invalid. Hon'ble Apex Court in case of UCO Bank (supra) held that the circular issued by CBDT in exercise of its statutory powers u/s 119 of the Act, are binding on the authorities. The Hon'ble Apex court held as under:- “The Central Board of Direct …” (source PDF page 4)

Judicial decision

“In the result, the appeal of the assessee is allowed.” (source PDF page 6)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Rajkot · 11 source pages

Nihal Projects

ITA Nos. 929/RJT/2024

In the result, the appeal is allowed in the terms indicated above.

Read the five-part AKHB brief

Facts of the case

“By way of this appeal, the assessee has challenged correctness of the order dated 17.10.2024 passed by the learned Commissioner of Income Tax (Appeals) [ in brief ‘CIT(A)’], in the matter of assessment under section 143(3) of the Income Tax Act 1961, for the assessment year 2017-18. 2.Grounds of appeal raised by the assessee are as follows.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard both the parties on this preliminary issue.Having considered the additional grounds of appeal filed, the issue involved has been carefully gone through and it is noticed that the additional ground of appeal is technical in nature and has synergies with the facts of the case and other grounds of appeal and we also noticed that the additional grounds of appeal is legal in nature and goes into roots of the matter and all the facts are already on record. Therefore following the principle of natural justice the same as admitted considering various judicial pronouncements noted hereunder; (i) Himachal Gramin Bank Vs. DCIT [2008] 305 …” (source PDF page 3)

Judicial decision

“In the result, the appeal is allowed in the terms indicated above.” (source PDF page 11)

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 8 source pages

Sangam Almirah Private Limited

I.T.A. No.: 338/PAT/2025

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

Read the five-part AKHB brief

Facts of the case

“This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals) -NFAC, Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2018-19 dated 10.06.2025, which has been passed against the penalty order u/s 270A of the Act, dated 10.02.2022. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1. For that the orders of the authorities below are bad in law and fact. 2. For that the learned CIT(A) is not justified in not adjudicating the specific grounds taken with regard to limitation of penalty proceeding and the” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have considered the rival submissions made, gone through the facts of the case and perused the record and the order of the Ld. CIT(A). The provisions of section 270AA are reproduced as under: “270AA. (1) An assessee may make an application to the Assessing Officer to grant immunity from imposition of penalty under section 270A and initiation of proceedings under section 276C or section 276CC, if he fulfils the following conditions, namely:— (a) the tax and interest payable as per the order of assessment or reassessment under sub-section (3) of section 143 or section 147, as the case may be, has been paid within the period specified in …” (source PDF page 5)

Judicial decision

“In the result, the appeal filed by the assessee is allowed.” (source PDF page 7)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Pune · 73 source pages

Poona Obstetrics and Gynaecological Society & others

ITA No.518/PUN/2023

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“These appeals at the instance of different assessees‟ are directed against the separate orders all evenly dated 06.03.2023 framed by PCIT (Central), Pune u/s.12AB(4) of the Income -tax Act, 1961 (in short „the Act‟). 2. As all the parties have admitted that most o f the issues involved in these appeals are common , we proceed to dispose of the same by this consolidated order for the sake of convenience and brevity. 3. In ITA No.518/PUN/2024 in the case of Poona Obstetrics and Gynaecological Society (in short „POGS‟) , assessee has raised following grounds of appeal : ―1. Learned PCIT -Central Circle, Pune erred in law and on facts in cancelling registration u/s .12A of …” (source PDF page 2)

Discussion by the Hon’ble Tribunal

“We have heard the rival contentions a nd perused the record placed before us. We have also considered the decisions relied on by both the parties. We will first take up the legal issued raised in the additional ground by POGS and MOGS stating that there was no powers with ld. PCIT to cancel the registration u/s.12A of the Act granted under the old regime in the order framed u/s.12AB(4) of the Act. Though the assessee has referred to plethora of decisions and have also referred to the relevant provisions of the Act, we find that recently the very issue has been dealt by us in the case of M.M. Patel Charitable Trust in ITA No.1130/PUN/2024 …” (source PDF page 40)

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Patna · 6 source pages

Raj Kumar Gupta

I.T.A. No.: 502/PAT/2024

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

Read the five-part AKHB brief

Facts of the case

“This appeal filed by the assessee is against the order of the Commissioner of Income Tax (Appeals) -NFAC, Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for AY 2017-18 dated 19.06.2024,” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“Having considered the appellant's submissions and the facts of the case. I hold the following views: It is found from the submission of the appellant, due to his lack of knowledge about income tax he could not file his return of income A.Y. in question. During the course of the assessment proceedings the A.O. has assessed the appellant's income on the basis of available bank transactions. AO has also identified Rs. 870440/- as business income and the balance amount of Rs. 7 ,11,000/-as unexplained cash credit but the appellant in his submission stated that the total transaction found in bank a/c was his business transaction. The appellant also stated that his business is best on 100% cash transaction. Fo r the appellant considering the provisions of section 44AD of the Act, paid a tax …” (source PDF page 3)

Judicial decision

“In the result, the appeal filed by the assessee is partly allowed.” (source PDF page 5)

Outcome — in favour of

Mixed or issue-specific disposition. Read each ground and the operative directions; the result must not be presented as a win on every issue.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Delhi · 2 source pages

Anita Tomar

ITA No.6455/Del/2025

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“This assessee’s appeal for assessment year 2016-17, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1080323022(1), dated 03.09.2025 involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. It emerges at the outset during the course of hearing that there arises the first and foremost issue of validity of the impugned reopening itself since the learned assessing authority had issued Assessee by Sh. Sankalp Malik, Adv. Sh. Sanjay Malik, adv. …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Source discrepancy: The source gives different pronouncement and closing dates (25 November and 3 December 2025). Verify the authenticated copy.

ITAT · Patna · 7 source pages

Gram Nirman Mandal

ITA No.: 336/PAT/2025

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

Read the five-part AKHB brief

Facts of the case

“This appeal filed by the assessee is against the order of the ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for AY 2018-19 dated 10.06.2025. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: “1) for that, As one of the oldest and pioneer organizations of Bihar, Gram Nirman Mandal (GNM) organised by LOKNAYAK JAI PRAKASH NARAYAN in the year 1954 and runs various programs like Krishi Vigyan Kendra for maximum agriculture yields, organizing various types of training and seminars, arrangement of improved …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have considered the submissions made, gone through the facts of the case and perused the record and the order of the Ld. CIT(A). The assessee has claimed to file 10B after the completion of the assessment proceeding. On account of delay in filing the appeal, the same was not considered in the appeal was dismissed on account of non-prosecution.” (source PDF page 4)

Judicial decision

“In the result, the appeal of the assessee is partly allowed for statistical purposes.” (source PDF page 6)

Outcome — in favour of

Assessee: procedural/statistical relief only. A remand or statistical allowance does not finally decide the underlying tax merits. Review the operative directions for each ground.

AKHB REVIEW POINT

Check the Form 10B filing record and the applicable condonation application before claiming exemption. The Assessing Officer’s examination follows the CIT(E)’s decision on condonation; this remand is not an automatic exemption.

ITAT · Hyderabad · 104 source pages

Chennamaneni Mithun Chand

ITA Nos.979 & 980/Hyd./2026

In the result, appeal ITA.No.980/Hyd./2026 of the assessee for the assessment year 2023-2024 is allowed. 29. To sum-up, both the appeals of the Assessee are allowed. A copy of this common order be placed in the respective case files

Read the five-part AKHB brief

Facts of the case

“These two appeals by the Assessee are directed against two separate Orders of the learned CIT(A)-11, Hyderabad dated 23.03.2026 and dated 25.03.2026 for the assessment years 2022-2023 and 2023-2024, respectively.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have considered the rival submissions as well as relevant material on record. There is no dispute that the assessee was subjected to search and seizure action u/sec.132 of the Act on 31.10.2022 and thereafter, the assessee filed the return of income on 30.12.2022 for the year under consideration. The limitation for completion of the assessment as per the provisions of sec.153(1) read with 4th proviso is 12 months from the end of the assessment year under consideration. For the sake of ready reference, sec.153C(1) with 4th proviso is quoted as under: “153. Time limit for completion of assessment, reassessment and recomputation. (1) No …” (source PDF page 9)

Judicial decision

“In the result, appeal ITA.No.980/Hyd./2026 of the assessee for the assessment year 2023-2024 is allowed. 29. To sum-up, both the appeals of the Assessee are allowed. A copy of this common order be placed in the respective case files” (source PDF page 103)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Calcutta High Court · 4 source pages

Little More Engineering Private Limited

Case reference: see original order

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

This brief does not reproduce a factual narrative. Read the complete order for the parties, procedural background and disputed issues.

Discussion by the Hon’ble Court

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Mumbai · 51 source pages

Sonu Sood

ITA No. 1840/MUM/2025

In the result, the appeals of the assessee are allowed partly for /2026.

Read the five-part AKHB brief

Facts of the case

“These three appeals by the assessee are directed against three separate orders, all dated 24.01.2025 Commissioner of Income Ld.CIT(A)] for assessment year respectively. As common issue and dispute appeals, therefore, all these three appeals disposed off by way of this consolidated order for sake of convenience and avoid writ petitioner facts. 2. Firstly, we take up the appeal for assessee filed as much as 17 grounds 36, but later on 19/06/2025 filed concise 7 grounds, which reproduced as under: 1. On the facts and in law, the Ld. Commissioner of Income Tax (Appeals) [in short Ld. CIT(A)] erred in confirming the addition made by the [in short …” (source PDF page 2)

Discussion by the Hon’ble Tribunal

“We have heard rival submissions of the parties on this preliminary issue of admissibility of additional grounds. Since these grounds challenge the very substratum of the reassessment proceedings and go to the root of the matter, we are of the Sonu Pankaj Shakti Sagar Sood ITA No. 1840 , 1843 & 1842 Assessment Year, which culminated into an Assessment Order dated On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in confirming the additions made by Ld. AO despite the fact that no incriminating material found against the Appellant in the search action carried out under Section 132 of the Act. On the facts and …” (source PDF page 9)

Judicial decision

“In the result, the appeals of the assessee are allowed partly for /2026.” (source PDF page 51)

Outcome — in favour of

Mixed or issue-specific disposition. Read each ground and the operative directions; the result must not be presented as a win on every issue.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Allahabad High Court · 13 source pages

Allahabad Income Tax Appeal 436 of 2012

INCOME TAX APPEAL No. - 436 of 2012

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“Present income tax appeal has been filed u/s 260A of Income Tax Act, 1961 (hereinafter referred to as 'the Act, 1961') against the order dated 16.11.2011 passed by Income Tax Appellate Tribunal, Agra Bench, Agra for the A.Y. 2002-03. 3. Present appeal was admitted on 27.03.2012 on the following substantial questions of law: "1. Whether the finding of the Tribunal that the notice under Section 148 of the Income Tax Act had been validly served on the appellant, by holding that the findings recorded in the Assessment Order and in the first appellate order were incorrect only because the envelope containing the unserved notice could not be found in the original records, is …” (source PDF page 1)

Discussion by the Hon’ble Court

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Rajkot · 28 source pages

Sonpal Exports Pvt. Ltd.

ITA No. 29/RJT/2018

In the result, appeal filed by the revenue is dismissed.

Read the five-part AKHB brief

Facts of the case

“By way of this appeal, the Revenue, has challenged correctness of the order dated 16.11.2017, passed by the learned CIT(A), in the matter of assessment under section 143(3) of the Income Tax Act 1961, for the assessment year 2012-13. Grievances raised by the Revenue, which are interconnected and will be taken up together, are as follows: “1. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of Rs. 13,96,33,023/- holding that provision of section 195 will not be applicable. 2. On the facts of the case and in law, the Ld. C.I.T. (A) erred in ignoring the facts that the assessee has failed to prove the genuineness of …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard both the parties and carefully gone through the submission put forth on behalf of the assessee, along with the documents furnished and the case laws relied upon, and perused the fact of the case including the findings of the ld CIT(A) and other materials brought on record. We note that an important objection of the Ld. DR for the revenue is that during the appellate proceedings, the assessee has submitted additional evidences, therefore, the matter may be remitted back to the file of the assessing officer for fresh adjudication. However, we note that assessee has submitted before ld CIT(A), merely supportive additional new …” (source PDF page 11)

Judicial decision

“In the result, appeal filed by the revenue is dismissed.” (source PDF page 27)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Delhi High Court · 3 source pages

Employees Provident Fund Organization

W.P.(C) 6049/2026

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

This brief does not reproduce a factual narrative. Read the complete order for the parties, procedural background and disputed issues.

Discussion by the Hon’ble Court

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Verify every cited authority against an authentic order. An AI-generated citation or quotation is not evidence of a precedent; assess the directions in this order separately from the underlying tax dispute.

ITAT · Mumbai · 19 source pages

Vinay Tarachand Chawla

ITA No. 3371/MUM/2025

In the result, the appeal of the assessee is allowed.

Read the five-part AKHB brief

Facts of the case

“This appeal by the assessee is directed against order dated 27.03.2025 passed by the Ld. Pr. Commissioner of Income-tax Mumbai-6 [in short ‘the Ld. PCIT’] for assessment year 2020-21, raising following grounds: Ground 1 & 2 - PCIT erred in passing the order u/s 263 of the Act which is bad in law, illegal, ultra-virus, in excess of and/or in want of jurisdiction and otherwise void.” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard rival submissions of the parties and perused the relevant materials on record invoked provisions of section 263 of the Act on two grounds. Firstly, the assessment order is deemed to be erroneous in so far as prejudicial to the interest of the Revenue in view of Explanation 2 to section 263 of the Act as t not carried out the inquiry which ought to have been carried out in the facts and circumstances of the case merit of the issues raised. The assessee are not found in order held the finding of the Assessing Office prejudicial to the interest of the Revenue. 5.1 As far as first reason for proceeding u/s 263 is concerned before …” (source PDF page 12)

Judicial decision

“In the result, the appeal of the assessee is allowed.” (source PDF page 19)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Allahabad High Court · 10 source pages

Harish Chandra Bhati

WRIT TAX No. - 465 of 2022

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

This brief does not reproduce a factual narrative. Read the complete order for the parties, procedural background and disputed issues.

Discussion by the Hon’ble Court

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

“the writ petition is disposed off giving liberty to the petitioner to avail statutory remedy of appeal or revision under the Act, 1961 as he may be advised. All pending applications are disposed off. 14. In view of the discussions made above, particularly considering the instructions dated 23.04.2022 issued by the CBDT in exercise of powers conferred under Section 119 of the Act, 1961 and the statement of the respondent No.4 made in para-10 of the personal affidavit filed on 19.05.2022, the following directions in the nature of mandamus are …” (source PDF page 9)

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Delhi · 18 source pages

Diamond Realcon Pvt. Ltd.

ITA No. 1259 & 1260/Del/2025

In the result, Appeal in ITA Nos. 1259/Del/202 5 and 1260/Del/2025 are allowed.

Read the five-part AKHB brief

Facts of the case

“The captioned Appeals are filed by the Assessee aga inst the orders of Ld. Commissioner of Income Tax (Appeals)-3, Gurg aon, (Ld. CIT(A)’ for short), dated 28/01/2025 for the Assessment Year 2 011-12 and 2012- 13 respectively. 2. The grounds of Appeal of Respective Appeals are as under:- ITA No. 1259/Del/2025 (A.Y. 2011-12) “1.0 That, on the facts and in the circumstances of the case, the disallowance, imposition of tax, and interest wi th reference thereto, as well as the quantification of taxable i ncome and tax liability, are unjustified, erroneous, and unsustain able, and it is prayed that necessary directions be issued to the Learned” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard both the parties and perused the m aterial available on record. It is the specific case of the Assessee that the notice u/s 148 of the Act was not digitally or manually signed. T he copy of the said notice is placed at page No. 11 of the PB. For the sake of ready reference, the copy of the notice issued u/s 148 of the Act 31/03/2018 is reproduced as under:-” (source PDF page 8)

Judicial decision

“In the result, Appeal in ITA Nos. 1259/Del/202 5 and 1260/Del/2025 are allowed.” (source PDF page 17)

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Mumbai · 6 source pages

Samsara Shipping Pvt. Ltd.

ITA No. 6724/Mum/2025

In the result, the appeal is allowed as indicated above.

Read the five-part AKHB brief

Facts of the case

“the present appeal, admittedly, in the demand notice issued along with the assessment order, the A.O. has specified “zero” demand. Therefore, based on such demand notice, the assessee was not required to pay any amount. Long after completion of assessment and issuance of demand notice of almost two years, the A.O. suddenly realized the mistake committed in the computation part of the assessment order, that too, based on revenue audit objection and passed an order u/s. 154 of the Act on 28.11.2024, revising the demand. In the computation sheet attached to the order passed u/s. 154 of the Act, the A.O. has charged interest u/s. 220(2) of the Act for an amount of …” (source PDF page 4)

Discussion by the Hon’ble Tribunal

“We have carefully considered the rival submissions and perused the materials available on record. A careful perusal of the order of assessment dated 22.12.2022, passed u/s. 143(3) r.w.s. 144B of the Act indicates that while completing the assessment, the A.O. did determine the total income at Rs.204,90,47,769/-, after making upward variation to the income declared by the assessee. However, in the computation sheet forming part of the assessment order, the A.O. computed the taxable income at Rs.55,22,22,410/- and tax liability at Rs.13,89,83,336/-. After adjusting the prepaid taxes of Rs.1424,25,387/-, the A.O. even computed refund due of …” (source PDF page 3)

Judicial decision

“In the result, the appeal is allowed as indicated above.” (source PDF page 5)

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

ITAT · Kolkata · 4 source pages

Anshul Kumar Rathi

ITA No.2776/Kol/2025

In the result, the appeal of the assessee is allowed. Kolkata,

Read the five-part AKHB brief

Facts of the case

“The present appeal has been preferred by the assessee against the order of the NFAC, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 13.10.2025passed u/s 250 of the Income Tax Act (hereinafter referred to as the ‘Act’) for the A.Y 2017-18. 2. The first issue raised is against the assumption of jurisdiction by the Assessing Officer ITO, Ward-3(2), Purulia u/s 147 of the Act by issuing notice u/s 148 instead of ACIT/DCIT, Circle-3, Asansol as the returned income of the assessee was above Rs.20.93 lakh. 3. We have heard the rival submissions. We find that in this case, the assessee has challenged the jurisdiction of the AO i.e. ITO ward-3(2), Purulia to issue …” (source PDF page 1)

Discussion by the Hon’ble Tribunal

“We have heard the rival submissions. We find that in this case, the assessee has challenged the jurisdiction of the AO i.e. ITO ward-3(2), Purulia to issue notice u/s 148 of the Act. We find the contention of the assessee to be true that the notice issued u/s 148 of the Act by the ITO, Ward-3(2), Purulia is without jurisdiction. The assessee has argued that” (source PDF page 1)

Judicial decision

“In the result, the appeal of the assessee is allowed. Kolkata, the 21st May, 2026.” (source PDF page 4)

Outcome — in favour of

Assessee, for the issues disposed of in the quoted result. Check the full reasoning for whether relief is substantive or procedural, and verify subsequent proceedings before relying on it.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Delhi High Court · 5 source pages

Grid Solutions SAS

W.P. (C) 16355/2025

Not independently classified; see the operative order.

Read the five-part AKHB brief

Facts of the case

“This petition is filed with the following prayers:- “a) a writ in the nature of certiorari/ mandamus or any other appropriate writ, order or direction for quashing the notice dated 30.03.2025 issued under section 148A(1) of the Act for assessment year 2019-20; b) a writ in the nature of certiorari/ mandamus or any other appropriate writ, order or direction for quashing the order dated 30.06.2025 passed by” (source PDF page 1)

Discussion by the Hon’ble Court

No separate discussion passage is reproduced in this extract brief. Consult the complete order; do not infer a holding from the filename or the parties’ submissions.

Judicial decision

The disposition is not classified in this brief. Read the final operative paragraphs and any schedules in the complete order.

Outcome — in favour of

The quoted result identifies the disposition of the appeals, rather than a universal ruling for all taxpayers. A merits or party-specific outcome is not independently certified in this source extract brief; verify every ground in the complete order.

AKHB REVIEW POINT

Read the numbered grounds and operative reasoning together. Match the statutory provision, assessment year, jurisdiction and material facts before relying on this order; check later appeals, stays and amendments.

Tax judgments & reference notes

Shri Swami Narayan Hari Mandir Trust

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Neeraj Sinha, HUF

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Ganadhipati Construction Pvt. Ltd.

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Vinayak Builders and Developers Pvt. Ltd.

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Vijaya Singh

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Patna Iron Pvt. Ltd. / Sushil Kumar Kanodia

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Jainam Ornament Pvt. Ltd.

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Sita Devi

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Sony India Pvt. Ltd.

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Amar Kasera (HUF)

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Mangadu Natarajan Balasundharam

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Shambhu Kumar Singh

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Kanaparthy Suryaprakasarao

Facts of the case

Discussion by the Hon’ble Tribunal

Judicial decision

Outcome — in favour of

AKHB REVIEW POINT

Chamber of Tax Consultants / BCAS