This compilation indexes 12 recent orders — from the Income Tax Appellate Tribunal (ITAT) benches at Mumbai, Kolkata, Ahmedabad, Bangalore, and Cochin, as well as the Karnataka High Court — in which Section 254 of the Income Tax Act, 1961 was directly engaged. The orders span the period October 2025 to July 2026 and cover the full procedural spectrum of Section 254's application: stay petitions filed under the proviso to sub-section (2A), miscellaneous applications invoking sub-section (2) for correction of mistakes apparent from record, substantive first appeals decided under sub-section (1), and High Court proceedings arising out of ITAT orders. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured starting point for case-law research on the Tribunal's appellate powers and associated procedural mechanisms.

Research index only. This page is a structured case-law reference compiled from publicly available tribunal and court orders. Nothing on this page constitutes legal advice, tax advice, or any form of professional opinion. Readers must independently verify all citations against the full text of the original judgment and should consult qualified professionals before taking any action.

The statutory framework in one paragraph

Section 254 of the Income Tax Act, 1961 governs the powers of the Income Tax Appellate Tribunal in disposing of appeals filed before it. Sub-section (1) empowers the Tribunal to pass such orders thereon as it thinks fit, after giving both parties a reasonable opportunity of being heard. Sub-section (2) provides that the Tribunal may, at any time within six months from the end of the month in which the order was passed, with a view to rectifying any mistake apparent from the record, amend any order passed by it. Sub-section (2A), introduced by the Finance Act, 2016, provides that the Tribunal shall, where it is possible, hear and decide every appeal within a period of four years from the end of the financial year in which such appeal is filed, and further provides — through its proviso — that in cases where a stay of demand has been granted, the Tribunal shall dispose of the appeal within the prescribed period, subject to the requirement that the assessee has paid not less than twenty per cent of the amount of tax, interest, fee, penalty, or any other sum payable under the provisions of the Act, or has furnished security of equal amount in respect thereof.

The 12 rulings

1. Late Bhagwanbhai Kalyanbhai Kukadiya vs DCIT Central Circle 3(1) , Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 7 July 2026
Sections engaged: 132, 142, 143(3), 153, 153A, 153C, 250, 254
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the ITAT Mumbai "B" Bench, with the assessee being represented by a legal heir following the death of the original appellant. Per the source preview, the proceedings involved ITA No. 1149/Mum/2026 and ITA No. 9483/Mum/2025, both pertaining to Assessment Year 2010-11, and the matter was heard on 1 July 2026 and 2 July 2026 before pronouncement on 7 July 2026. The sections engaged indicate the appeal arose in the context of search-related assessment proceedings, with the order of the Tribunal being passed under the provisions of Section 254.

2. 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 is a stay petition (SA No. 30/KOL/2026 arising out of ITA 1343/KOL/2026) filed before the ITAT Kolkata 'A' Bench for Assessment Year 2020-21, seeking a stay of a demand of ₹2,59,10,104/- raised by the Assessing Officer and confirmed by the CIT(A). Per the source preview, the Tribunal enquired from the assessee's representative whether twenty per cent of the demand had been paid as required under the proviso to sub-section (2A) of Section 254 of the Act — a condition precedent to the grant of a stay in the context of a pending appeal. The assessee is described as an individual who is the proprietor of Asian Diesel Spares, with income from business and other sources.

3. Manish N. Amin,Ahmedabad vs The ITO, Ward-3(3)(2), Ahmedabad

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 6 July 2026
Sections engaged: 254(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a Miscellaneous Application (MA No. 46/Ahd/2026) filed by the assessee in respect of the Tribunal's order in ITA No. 88/Ahd/2026 dated 10 March 2026 for Assessment Year 2017-18, invoking the rectification jurisdiction under Section 254(2). Per the source preview, the assessee's representative submitted that there was a mistake apparent from record in paragraph 10 of the Tribunal's order, wherein a finding was given that additional evidences filed by the assessee were not linked with the invoices — whereas, the representative contended, the assessee had in fact attached Aadhaar/PAN documents and invoice-wise customer identification documents in the paper-book immediately after the relevant entries.

4. Mandya Zilla Padavipoorva Colleju vs ITO, Ward-1 & Tps, Mandya

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 6 July 2026
Sections engaged: 254(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a stay application (SA No. 82/Bang/2026) filed by the assessee society before the ITAT Bangalore "C" Bench, arising out of ITA No. 2155/Bang/2026 for Assessment Year 2019-20. Per the source preview, the application sought a stay of disputed demand amounting to Rs. 3,50,25,725/- consequent to an assessment order, and the assessee's representative submitted arguments before the Tribunal regarding the circumstances of the assessment. The stay application was filed invoking the Tribunal's jurisdiction in the context of a pending appeal under Section 254(1).

5. Kerala State Co Operative Marketing vs Assistant Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Cochin
Date: 3 July 2026
Sections engaged: 254(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a stay application (SA No. 25/Coch/2026) filed by the assessee before the ITAT Cochin Bench (Virtual Hearing), arising out of ITA No. 402/Coch/2026 for Assessment Year 2013-14. Per the source preview, the application sought a stay of disputed demand amounting to Rs. 28,54,488/- arising out of a re-assessment order, and the source preview records instalment payments made by the assessee on various dates totalling Rs. 33,85,060/-. The matter was taken up in the context of a pending appeal before the Tribunal under Section 254(1).

6. Ananthapuram Co-Operative vs Income Tax Officer, Ward TDS

Bench: Income Tax Appellate Tribunal - Cochin
Date: 3 July 2026
Sections engaged: 253(1), 253(5), 254
Outcome: Outcome not specified in source
Procedural / substantive ground: These are consolidated stay applications (SA Nos. 22 to 24/Coch/2026) filed by the assessee society before the ITAT Cochin Bench (Virtual Hearing), arising out of ITA Nos. 323, 322, and 328/Coch/2026 for Assessment Years 2013-14, 2014-15, and 2015-16 respectively. Per the source preview, the applications sought a stay of disputed demands amounting to Rs. 49,19,653/- for Assessment Year 2013-14, Rs. 59,23,371/- for Assessment Year 2014-15, and Rs. 53,14,103/- for Assessment Year 2015-16. The stay applications were filed in connection with pending appeals before the Tribunal under Section 254.

7. ITO, Ward - 1(1),, Kolkata vs M/S. Baid Trade Fina Pvt. Ltd.,, Kolkata

Bench: Income Tax Appellate Tribunal - Kolkata
Date: 2 July 2026
Sections engaged: 115B, 254(1), 254(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a Miscellaneous Application (MA No. 54/KOL/2026 in ITA No. 2453/KOL/2024) filed at the instance of the Revenue before the ITAT Kolkata 'SMC' Bench, directed against the Tribunal's order dated 30 April 2025, for Assessment Year 2021-22. Per the source preview, the Revenue filed the petition on the ground concerning non-allowability of taxation at a lower rate under Section 115BAA in the return, invoking the Tribunal's rectification jurisdiction under Section 254(2). The matter was heard on 12 June 2026 and the order pronounced on 2 July 2026.

8. Himmadihalli Bachanna Krishna vs Income-Tax Officer, Ward - 4(2)(2)

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 30 June 2026
Sections engaged: 133A, 147, 2(47), 2(47)(v), 250, 254, 53A
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a substantive appeal (ITA No. 479/Bang/2026) filed by the assessee before the ITAT Bangalore 'A' Bench for Assessment Year 2011-12, directed against the order of the Commissioner of Income Tax (Appeals) at the National Faceless Appeal Centre, Delhi, dated 12 January 2026, under the provisions of Section 250 read with Section 254. Per the source preview, the assessee raised several grounds of appeal numbered 1 to 9, and the order notes that the effective interconnected issue raised was considered by the Tribunal. The diversity of sections cited indicates the appeal involved issues relating to the nature of a transaction and the character of income or asset transfer.

9. Soham Data Processing & Finance Private vs Income Tax Circle 16(2) Mumbai, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 11 June 2026
Sections engaged: 143(3), 254
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (I.T.A. No. 1432/Mum/2026) was filed before the ITAT Mumbai "SMC" Bench for Assessment Year 2003-04. Per the source preview, the proceedings involved a detailed income computation including rent received, maintenance charges received, various disallowances including rent paid, maintenance charges on account of salary and bonus, administrative charges, and salary and bonus, with the Tribunal engaging with the computation in the course of its order under Section 254. The matter was heard on 14 May 2026 and the order was pronounced on 11 June 2026.

10. DCIT 19 1 Mumbai, Mumbai vs Naozer Bejon Baldawala, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 11 June 2026
Sections engaged: 143(3), 254
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 2340/Mum/2026) was filed by the Revenue before the ITAT Mumbai 'B' Bench for Assessment Year 2010-11. Per the source preview, the Tribunal, taking note of a grievance that cross-examination had remained unadjudicated, recalled its earlier order and restored the matter to the file of the Assessing Officer with specific directions to furnish copies of statements relied upon by the Department, afford an opportunity of cross-examination of the concerned parties, and thereafter pass a fresh order in accordance with law. The matter was heard on 21 May 2026 and the order pronounced on 11 June 2026.

11. The Pr., Commissioner Of Income Tax-1 vs Airbus India Pvt Ltd

Bench: Karnataka High Court
Date: 9 March 2026
Sections engaged: 143(3), 254
Outcome: Outcome not specified in source
Procedural / substantive ground: This is a Review Petition (RP No. 41 of 2026) filed before the Karnataka High Court at Bengaluru, seeking review of an order dated 28 October 2025 passed by the High Court in WP No. 24690/2025. Per the source preview, the petition was filed under Section 114 read with Order 47 Rule 1 of the CPC, 1908, and the petitioners sought a review of the earlier High Court order. The proceedings arose in the context of income-tax matters involving the Tribunal's order under Section 254 and a scrutiny assessment under Section 143(3), and the source preview notes that the matter was heard and the arguments of counsel for both sides were considered.

12. The Principal Commissioner Of vs Shri. S.S. Bakkesh

Bench: Karnataka High Court
Date: 13 October 2025
Sections engaged: 254
Outcome: Outcome not specified in source
Procedural / substantive ground: This is an income tax appeal (ITA No. 72 of 2020 C/W ITA No. 37 of 2020) filed before the Karnataka High Court at Bengaluru under Section 260A of the Income Tax Act, 1961, arising out of orders passed by the ITAT Bengaluru in M.P. No. 266/Bang/2018 (in ITA No. 229/Bang/2013) dated 21 June 2019 for Assessment Year 2008-09. Per the source preview, the Revenue prayed for the High Court to set aside the ITAT's orders confirming the order of the appellate commissioner, and to confirm the order passed by the Deputy Commissioner of Income Tax, Central Circle-1(3), Bengaluru. The appeal directly challenges a ruling made under Section 254 by the Tribunal.

Patterns across these 12 rulings

Stay petitions are a dominant procedural mode. A significant number of the orders in this set — Cases 2, 4, 5, and 6 — are stay applications filed under the proviso to Section 254(2A), with assessees seeking a stay of demand pending disposal of substantive appeals. The common thread across these matters is the Tribunal's inquiry into whether the condition of payment of a portion of the disputed demand had been satisfied, consistent with the statutory framework governing the grant of stay in pending appeals.
Miscellaneous applications invoking Section 254(2) arise both from assessees and the Revenue. Cases 3 and 7 both involve miscellaneous applications invoking the Tribunal's rectification jurisdiction: Case 3 is filed by the assessee on the ground of an alleged mistake apparent from record in the Tribunal's earlier finding, while Case 7 is filed by the Revenue challenging the Tribunal's earlier order. This pattern illustrates that the Section 254(2) rectification route is actively used by both sides of litigation.
Matters spanning multiple assessment years are consolidated before the same bench. Case 6 (Ananthapuram Co-Operative) involves three consolidated stay applications for Assessment Years 2013-14, 2014-15, and 2015-16 heard together by the same bench. This procedural consolidation is a recurring feature in ITAT practice where common parties and common questions arise across multiple years.
High Court proceedings in this set arise as downstream challenges to ITAT orders under Section 254. Cases 11 and 12 both arise before the Karnataka High Court, with the Revenue challenging ITAT orders — one through a review petition before a Single Judge and the other through a Section 260A appeal before a Division Bench. This pattern reflects the role of Section 254 as the upstream source of rights that are then contested in higher forums.
Procedural diversity within Section 254. The cases in this set engage different sub-provisions of Section 254 — sub-section (1) for first appellate orders (Cases 4, 5, 8, 9, 10), sub-section (2) for miscellaneous applications / rectification (Cases 3, 7), and sub-section (2A) for stay petitions (Cases 2, 4, 5, 6) — illustrating that Section 254 functions as a multi-layered provision serving distinct procedural purposes within the appellate framework.

How to use this compilation

This compilation is structured as a research index and is not a substitute for reading the full text of each judgment. Each entry in this article provides only a high-level identification of the parties, bench, date, sections engaged, and the procedural or substantive ground as discernible from the source preview. Researchers should obtain the complete order from indiankanoon.org, the ITAT's official e-filing portal, or the relevant High Court's official website before relying on any ruling for any purpose. It is essential to verify that the order has not subsequently been stayed, reversed, modified, or appealed to a higher forum.

When using ITAT orders for research purposes, researchers should check for any CBDT circulars, instructions, or clarifications that may have been issued on the same subject matter, as departmental instructions can affect how a ruling is applied in practice. Similarly, researchers should check whether the assessee or the Revenue has filed an appeal to the High Court under Section 260A or sought a writ remedy, which could affect the precedential value of the ITAT order. In matters where a stay of demand has been granted by the Tribunal, the terms of the stay and any conditions imposed should be read from the full order.

Researchers are also advised to note that the orders in this compilation were sourced as per the text_preview available in the TaxNoticeAI structured corpus, and in several instances the outcome direction is recorded as "Outcome not specified in source," meaning the operative finding of the Tribunal is not reproduced in the preview extract. Accordingly, no inference should be drawn about the final disposition of any case from this index alone. Always read the full order and, where relevant, trace the case through all appellate stages.

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.

Section 254 ITAT Powers: 12 Recent Rulings on Appeals, Stay Petitions & Miscellaneous Applications (2025–2026)