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Section 253 Income Tax Appeals: 12 ITAT Rulings (June–July 2026)

A structured index of 12 recent ITAT rulings under Section 253 of the Income Tax Act, 1961, covering second appeals filed by assessees and Revenue across Indore, Bangalore, and Kolkata benches in June–July 2026.

Rangoli Bansal11 min read

This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) orders pronounced between 30 June 2026 and 10 July 2026, all engaging Section 253 of the Income Tax Act, 1961. The cases span the ITAT Indore, ITAT Bangalore, and ITAT Kolkata benches and cover a range of substantive issues — including unexplained money, charitable trust exemptions, best-judgment assessments, penalty proceedings, search matters, and stay petitions — that arise at the second-appeal stage. This index is intended for use by in-house tax teams, Big-4 associates, and law firm researchers tracking the volume and character of Section 253 filings at the ITAT level.

Research index only. This page is a structured case-law reference tool, not legal or tax advice. Readers should verify every ruling against the full judgment text and consult qualified advisers before acting on any information presented here.


The statutory framework in one paragraph

Section 253 of the Income Tax Act, 1961 governs appeals to the Income Tax Appellate Tribunal (ITAT). It specifies the categories of orders against which an appeal lies to the Tribunal — including orders passed by a Commissioner (Appeals) under Sections 250, 154, or 271, and orders passed by a Principal Commissioner or Commissioner under Sections 12AA, 263, or 271, among others. Both the assessee and the Assessing Officer (on behalf of the Revenue) may file appeals under this section, subject to the prescribed time limits and procedural requirements. The Tribunal constitutes the final fact-finding authority in income-tax proceedings, and its orders under Section 254 are binding on lower authorities for the same assessee in respect of the same assessment year.


The 12 rulings

1. Smt. Poonam Rathore,Sehore vs Income-Tax Officer, Sehore, Sehore

  • Bench: Income Tax Appellate Tribunal - Indore
  • Date: 10 July 2026
  • Sections engaged: 253, 56(2)(vii)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The appeal was filed by the assessee under Section 253 before the ITAT Indore as a second appeal, being aggrieved by order no. ITBA/APL/S/250/2025-26/1083000495(1) dated 26.11.2025 passed by the CIT(A). The relevant assessment year per the source preview is 2011-12 (ITA No. 302/Ind/2026, PAN: DXOPR0409C), corresponding to the previous year period 01.04.2010 to 31.03.2011.

2. Chogalal Prakash Chandra,Neemuch vs Income-Tax Officer, Neemuch

  • Bench: Income Tax Appellate Tribunal - Indore
  • Date: 10 July 2026
  • Sections engaged: 06, 253
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: This appeal was filed by the Revenue under Section 253 before the ITAT Indore, being aggrieved by order no. ITBA/APL/S/250/2025-26/1080411927(1) dated 08.09.2025 passed by the CIT(A). Per the source preview, the relevant assessment year is 2013-14 (ITA No. 976/Ind/2025, PAN: AAAFC6120H), and the previous period corresponds to 01.04.2012 to 31.03.2013.

3. Shri Shriram Parmarthik Trust,Indore vs Income Tax Officer Ward Exemption

  • Bench: Income Tax Appellate Tribunal - Indore
  • Date: 9 July 2026
  • Sections engaged: 11, 253
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee, a trust, filed this second appeal under Section 253 before the ITAT Indore, being aggrieved by order no. ITBA/APL/S/250/2025-26/1085126100(1) dated 23.01.2026 passed by the CIT(A). Per the source preview, the relevant assessment year is 2019-20 (ITA No. 294/Ind/2026, PAN: AAMTS3042G), corresponding to the previous year period 01.04.2018 to 31.03.2019.

4. Ikram Uddin,Bhopal vs ITO,4(1), Bhopal, Bhopal

  • Bench: Income Tax Appellate Tribunal - Indore
  • Date: 9 July 2026
  • Sections engaged: 144(1)(a), 253
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee filed this second appeal under Section 253 before the ITAT Indore, being aggrieved by order no. ITBA/APL/S/250/2025-26/1076542839(1) dated 29.05.2025 passed by the CIT(A). Per the source preview, the relevant assessment year is 2017-18 (ITA No. 339/Ind/2026, PAN: AAZPU5464D), corresponding to the previous year period 01.04.2016 to 31.03.2017.

5. Kodiambadi Subrahmanya Rai,Mysuru vs Addl.CIT (Central Range)-3 Blr

  • Bench: Income Tax Appellate Tribunal - Bangalore
  • Date: 8 July 2026
  • Sections engaged: 132(4), 246, 246A, 253, 263, 264, 269S, 271D, 274, 275(1), 275(1)(a), 275(1)(b)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: Four appeals (ITA Nos. 2814, 2815, 2816 & 2817/Bang/2025) pertaining to assessment years 2016-17, 2017-18, 2018-19, and 2020-21 were heard together and decided by a consolidated order, as all appeals pertain to the same assessee involving similar issues arising out of a similar factual matrix. Per the source preview, the assessee's appeal for assessment year 2016-17 was treated as the lead case, with the decision to apply mutatis mutandis to the remaining appeals (PAN: AFGPR1192F).

6. Fakhruddin Husainibhai,,Kolkata vs DCIT, Central Circle 1(4),, Kolkata

  • Bench: Income Tax Appellate Tribunal - Kolkata
  • Date: 7 July 2026
  • Sections engaged: 253, 254
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: This proceeding is a stay petition (SA No. 30/KOL/2026 arising out of ITA No. 1343/KOL/2026) filed for staying a demand of ₹2,59,10,104/- for AY 2020-21 raised by the Assessing Officer, which had also been confirmed by the CIT(A). Per the source preview, the assessee is an individual and proprietor of Asian Diesel Spares with income from business and other sources; the bench enquired whether 20% of the demand had been paid as required under the proviso to sub-section (2A) of Section 254 (PAN: AAQPH3249A).

7. Vidit Garg,Indore vs Assessing Officer, Gwalior

  • Bench: Income Tax Appellate Tribunal - Indore
  • Date: 6 July 2026
  • Sections engaged: 142, 144, 253, 271(1)(b), 273B
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: Seven appeals (ITA Nos. 586 to 592/Ind/2026) covering assessment years 2015-16 to 2021-22 were placed before the bench. Per the source preview, the assessment order for AY 2015-16 was passed computing and assessing the total income of the assessee at Rs. 4,41,260/-, and the source records that questionnaires were issued for AY 2015-16 to 2021-22 (PAN: BAVPG2982D).

8. Smt Kanta Lalwani,Bhopal vs CIT-Appeal, Bhopal

  • Bench: Income Tax Appellate Tribunal - Indore
  • Date: 6 July 2026
  • Sections engaged: 144, 253
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee filed this appeal under Section 253 before the ITAT Indore, being aggrieved by order no. ITBA/APL/S/250/2025-26/1081772319(1) dated 15.10.2025 passed by the CIT(A). Per the source preview, the relevant assessment year is 2011-12 (ITA No. 232/Ind/2026, PAN: AAGPL3106J), and the source preview records multiple prior hearing dates before the final pronouncement on 06.07.2026.

9. Navalsingh Sahakari Shakkar Kharkhana vs Deputy Commissioner Of Income Tax

  • Bench: Income Tax Appellate Tribunal - Indore
  • Date: 6 July 2026
  • Sections engaged: 253, 44
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee filed this second appeal under Section 253 before the ITAT Indore, being aggrieved by order no. ITBA/NFAC/S/250/2025-26/1079882410(1) dated 22.08.2025 passed by the National Faceless Appeal Centre (NFAC), Delhi. Per the source preview, the relevant assessment year is 2017-18 (ITA No. 897/Ind/2025, PAN: AAAAN5294N), corresponding to the previous year period beginning 01.04.2016.

10. Kishore Gupta,Arera Colony vs ACIT-1(2), Hoshangabad Road

  • Bench: Income Tax Appellate Tribunal - Indore
  • Date: 30 June 2026
  • Sections engaged: 253
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The appeal was filed by the assessee under Section 253 before the ITAT Indore. Per the source preview, the case involves search proceedings with jewellery and cash found and seized at the assessee's residence located at E-1/207, Arera Colony, Bhopal; the relevant assessment year is 2011-12 (ITA No. 1114/Ind/2025, PAN: AAWPG4766F).

11. Deputy Commissioner Of Income Tax 3 (1) vs M/S Krishidhan Seeds Private Limited

  • Bench: Income Tax Appellate Tribunal - Indore
  • Date: 30 June 2026
  • Sections engaged: 253
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: This matter involves both a Revenue appeal (ITA No. 200/Ind/2018) and a cross-objection (CO No. 34/Ind/2018) filed by the assessee company, both for assessment year 2011-12 (PAN: AABCK1652N). Per the source preview, the assessment involved multiple additions and disallowances including agriculture income treated as business income, disallowance of donation, provision for leave encashment and gratuity, and various other disallowances, with a gross total income computation reflected in the order.

12. Bhure Lal,Khandwa vs ITO-2, Khandwa

  • Bench: Income Tax Appellate Tribunal - Indore
  • Date: 30 June 2026
  • Sections engaged: 10, 115B, 253, 34, 69A
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee filed this second appeal under Section 253 before the ITAT Indore, being aggrieved by order no. ITBA/NFAC/S/250/2025-26/1078775074(1) dated 22.07.2025 passed by the CIT(A). Per the source preview, the relevant assessment year is 2017-18 (ITA No. 835/Ind/2025, PAN: AHTPL7795F), corresponding to the previous year period 01.04.2016 to 31.03.2017.

Patterns across these 12 rulings

  1. Assessee-initiated second appeals dominate the set. The majority of the twelve rulings reflect appeals filed by assessees under Section 253, challenging CIT(A) orders. Revenue-initiated appeals (such as Case 2 and Case 11) represent a minority of the filings, consistent with the general appellate pattern at the ITAT level.

  2. National Faceless Appeal Centre (NFAC) orders feature as the immediate trigger. In at least two cases (Cases 9 and 12), the impugned order challenged before the ITAT was passed by the NFAC, Delhi, rather than a conventional jurisdictional CIT(A). This reflects the progressive migration of first-appeal disposals to the faceless platform, with second appeals continuing to flow to the geographically relevant ITAT bench.

  3. Best-judgment and ex-parte assessment orders recur as the underlying assessment basis. Cases 4, 8, and 12 each involve assessments under Section 144, indicating that non-compliance or non-appearance at the assessment stage is a recurring factual backdrop for Section 253 second appeals in this data set.

  4. Consolidation of multiple assessment years in a single appeal proceeding. Cases 5 and 7 each involve multiple assessment years heard together and disposed of by a single consolidated order. This procedural efficiency — particularly where the assessee and the issues involved are common — is a visible feature of current ITAT practice.

  5. Proceedings at an early or procedural stage limit substantive disclosure. All twelve source previews are either procedural in nature (identifying parties, ITA numbers, assessment years, and the impugned order details) or truncated before substantive reasoning is disclosed. Accordingly, final holdings and dispositive directions cannot be confirmed from the available source data alone.


How to use this compilation

This index is designed as a starting point for legal research, not a substitute for reading the full judgment. Each entry provides the core identity fields — bench, date, ITA number (where visible in the source preview), assessment year, and sections engaged — to allow researchers to locate the original order on indiankanoon.org, the ITAT's official portal, or the relevant ITAT bench's record system. Researchers should verify that the order they retrieve matches the ITA number, PAN, and assessment year reflected in the source preview before relying on any holding.

When using this index for advisory or litigation purposes, it is essential to check whether any of these orders have been stayed, appealed further to a High Court under Section 260A, or revised. ITAT orders, while binding on the parties and lower authorities for the relevant assessment year, do not constitute precedent binding on other benches unless delivered by a Special Bench. Researchers should also cross-reference any relevant CBDT circulars, instructions, or clarifications that may affect the interpretation of the substantive sections cited alongside Section 253 in each case.

Finally, note that all outcome fields in this compilation reflect "Outcome not specified in source." This means the source preview available in the TaxNoticeAI corpus was insufficient to confirm the final direction of the order. Researchers tracking the outcome of any specific matter should retrieve the full judgment text and review the dispositive paragraph before drawing conclusions about the Tribunal's holding.


Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

RB

Rangoli Bansal

Editorial Reviewer & CA Finalist

CA Finalist (ICAI), B.Com (Hons.) Delhi University. 7+ years across audit, internal controls, SOX 404, ICFR, RCSA, and GRC. Hands-on experience with GST and income-tax compliance filings, statutory audit, and internal audit. Editorial reviewer for TaxNoticeAI's case-law content.

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Disclaimer: The information provided is for educational and informational purposes only and should not be construed as legal or tax advice. AI-generated content is a draft for professional review — always verify with applicable laws, circulars, and case law before filing. Consult a qualified Chartered Accountant or tax professional before acting on any information presented here.