MANNIRANJAN JAGADGURU MURUGARAJENDRA PRASAD NILAYA ,DHARWAD vs. INCOME TAX OFFICER EXEMPTIONS WARD -1 , HUBBALI

ITA 1560/BANG/2026Status: DisposedITAT Bangalore22 September 2026AY 2017-184 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal admitted the additional evidence, finding that it went to the root of the matter on which additions were made by the revenue authorities. Since these documents were not available before the revenue authorities, the Tribunal deemed it fit to restore the matter to the file of the Assessing Officer (AO). The AO is directed to examine the additional evidence furnished by the assessee and decide the issue in accordance with the law, providing the assessee an opportunity of being heard. As the issue is remanded back to the AO, the other grounds raised by the assessee before the Tribunal were not adjudicated and were left open. The appeal was allowed for statistical purposes.

What were the facts?

The assessee, Manniranjan Jagadguru Murugarajendra Prasad Nilaya, a trust, failed to file its return of income for Assessment Year 2017-18. The Assessing Officer (AO) reopened the case under Section 147 and issued a notice under Section 148. The assessee subsequently filed a return declaring a total income of Rs. 5,17,198/-. During the assessment, the AO noted fixed deposits of Rs. 1,79,22,828/- as of March 31, 2017, and agricultural income of Rs. 25,10,649/- with expenditure of Rs. 62,497/-. Lacking evidence for agricultural income, the AO added Rs. 20,32,003/- to the total income. The assessee's appeal to the CIT(A) was dismissed for not producing documentary evidence. The assessee then appealed to the ITAT, seeking to admit additional evidence.

What were the issues?

1. Whether the Tribunal should admit additional evidence, namely a lease agreement, transaction-wise break-up of lease rent receipts, and Aadhaar cards of lessees, which were not produced before the revenue authorities? (Question of mixed law and fact, relating to Rule 29 of ITAT Rules, 1963). Assessee's Contention: The assessee argued that the failure to file the additional evidence before the revenue authorities was not intentional or deliberate, and these documents are crucial to the appeal. Therefore, they should be admitted. Revenue's Contention: The Revenue strongly objected to the admission of the additional evidence.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 142(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI BALAKRISHNAN S & SHRI SOUNDARARAJAN K.

For Respondent: Shri. Pradeep S - Addl. CIT
Pronounced: 22.09.2026

PER SHRI BALAKRISHNAN S, ACCOUNTANT MEMBER:

This appeal is filed by the assessee against the order of Ld. National Faceless Appeal Centre (NFAC) vide DIN: ITBA/NFAC/S/250/2025-26/1085977850(1) dated 13-Feb-2026 for the Assessment Year 2017-18. 2. Briefly stated the facts of the case are that the assessee is a trust and had not filed the return of income for the

The order continues below.

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