2026 (3) TMI 1271

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....bhav, CA For Respondent/Revenue : Shri Ravi Kant Chaudhary, Sr. DR ORDER PER AMITABH SHUKLA, AM, This appeal by the assessee is directed against the order of the Addl/JCIT (Appeals)-4, Hyderabad, [hereinafter referred to as 'ld. CIT(A)] dated 31.10.2025 arising out of assessment order dated 28.12.2024 passed under section 143(3) of the Income Tax Act, 1961, for the Assessment Year 2024....

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....he Ld Addl/JCIT(A) -4 Hyderabad failed to consider the effect of CBDT Circular: No. 320[F. No. 131(31)/81-TP(PL)], dated 11-01-1982. 3. That on the facts and in the circumstances of the case and in law, the Ld Addl/JCIT(A) -4 Hyderabad erred in applying provisions of section 167B read along with section 160 & 164 of the Income Tax Act 1961 and denying the benefit of maximum amount not cha....

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.... CPC vide order dated 28.12.2024. Through the impugned order, the CPC exposed assessee's income to maximum marginal tax (MMR) i.e. tax @30% and surcharge @25%. The assessee contested that as its total income is Rs. 1,45,720/-, it is not exigible to MMR. The ld. First Appellate Authority did not concur with the arguments raised by the assessee and confirmed the order of the CPC. The ld. DR relied u....