SRIMAD JAGADGURU MADHWACHARYA MOOLA MAHASAUNSTHAN UTTARADIMATH,BANGALORE vs. DCIT EXEMPTIONS CIRCLE-1 BANGALORE, BANGALORE

ITA 2987/BANG/2026Status: DisposedITAT Bangalore08 October 2026AY 2015-1611 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal decided to condone the delay of 756 days in filing the appeal before the learned CIT(A). While acknowledging the lack of contemporaneous medical evidence, the Tribunal found that refusing to condone the delay could lead to a meritorious case being dismissed prematurely. Given the assessee's contention of a potential double addition (transactions already processed under the new PAN), the Tribunal felt that substantial justice would be served by hearing the case on merits. On the merits of the case, the Tribunal noted that a new PAN was allotted in 2014, and the return for the year under consideration was filed under this new PAN. The Tribunal also observed that for assessment year 2016-17, similar reassessment proceedings initiated under the old PAN were dropped after the assessee's submission that the transactions were accounted for and declared under the new PAN. Therefore, the Tribunal restored the matter to the Jurisdictional Assessing Officer (AO) for de novo assessment. The AO was directed to examine the assessee's contention regarding the disclosure of impugned deposits under the new PAN. If found correct, the AO was directed to delete the additions, as double addition is not permissible. The penalty proceedings were also restored to the AO for fresh consideration. The impugned orders in quantum and penalty proceedings were set aside.

What were the facts?

The assessee, Srimad Jagadguru Madhwacharya Moola Mahasaunsthan Uttaradimath, a religious institution registered under section 12A, appealed against orders for assessment year 2015-16. The assessee had two PANs: an old one (AACTS8831R) and a new one (AAAJS5099K) allotted on 03/01/2014. The assessee stopped using the old PAN and its e-filing portal. Due to delays in updating bank records, some transactions were reported under the old PAN. Notices under section 148A(b) for cash and time deposits were issued under the old PAN. As these went unanswered, reassessment proceedings under section 147 read with section 144 were initiated, treating deposits as unexplained. The assessee's appeal to the CIT(A) was dismissed for a delay of 756 days.

What were the issues?

1. Whether the Tribunal should condone the delay of 756 days in filing the appeal before the learned CIT(A), considering the reasons provided by the assessee? - Assessee's contention: The delay was due to the serious illness of its Chartered Accountant, who was in a coma for over six months, and the belief that the auditor had filed the appeal. The assessee also highlighted that a similar addition was dropped for AY 2016-17 and that the transactions were already disclosed under the new PAN, raising a concern of double addition. - Revenue's contention: The assessee failed to provide material to substantiate the reasons for seeking condonation of delay. 2. On merits, whether the additions made on account of cash deposits, time deposits, and interest income are to be deleted, given the assessee's claim that these transactions were already disclosed under its new PAN? - Assessee's contention: All transactions reported under the old PAN were duly recorded in the books of account, reflected in financial statements, and declared in the return of income filed under the new PAN for the assessment year 2015-16. The assessee also pointed to a similar issue for AY 2016-17 where reassessment proceedings were dropped after accepting this plea. - Revenue's contention: The assessee's claim that cash deposits were duly disclosed in the return of income filed under the new PAN requires verification.

Which sections of the Income-tax Act were involved?

Section 12A,Section 148A,Section 147,Section 144,Section 144B,Section 143(1),Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SANDEEP SINGH KARHAIL

PER SANDEEP SINGH KARHAIL, JUDICIAL MEMBER:

The assessee has filed the present appeals against the separate impugned orders of even date 22/06/2025, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appe

The order continues below.

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