ITAT Ahmedabad Judgments — June 2026

The Tribunal held that the CIT(E) erred in rejecting the application without proper service of notice and affording adequate opportunity. The principles of natural justice were violated by issuing notices to an incorrect email address.

The Tribunal set aside the CIT(E)'s orders and restored the matter for fresh decision. The assessee will be given an adequate opportunity to present their case before the CIT(E).

The Tribunal held that the CIT(E) erred in rejecting the application without proper service of notice and affording adequate opportunity. The principles of natural justice were violated by issuing notices to an incorrect email address.

The Tribunal upheld the PCIT's order, finding that the Assessing Officer had not adequately verified the provision for bad and doubtful debts and the loss on sale of assets. The Tribunal also directed the Assessing Officer to re-compute brought forward unabsorbed losses and depreciation after giving effect to appellate orders.

The ITAT found that the CIT(A) erred in ignoring the assessee's submission made on 27.12.2025, even though it was filed after the allowed timeline but was available to the CIT(A) when passing the order. The matter was set aside to the CIT(A) for re-adjudication on merits.

The Tribunal condoned the delay in filing the appeal and set aside the order of the CIT(E). The matter was restored to the CIT(E) for fresh adjudication, granting the assessee one more opportunity to present its case and documents.

The Tribunal held that the interests of justice would be served by remanding the matter back to the CIT(E) for fresh consideration, allowing the assessee an opportunity to submit their explanations and documents.

The Tribunal held that the interests of justice would be served by remanding the matter back to the CIT(E) for fresh consideration, allowing the assessee an opportunity to submit their explanations and documents.

The Tribunal held that the reassessment proceedings were valid as the notice was issued within the prescribed time limit and the approval for reopening was obtained from the competent authority. The donation was found to be part of a bogus accommodation entry arrangement, making the deduction claim invalid.

The Tribunal held that the assessee was justified in not deducting tax at source due to the interim directions from the Madras High Court, which stated that LFC payments would not be treated as income and no tax was to be deducted thereon.

The Tribunal set aside the orders of the CIT(E) and restored the applications back to the CIT(E)'s file. The assessee was granted another opportunity to furnish the necessary documents and submissions.

The Tribunal held that the rejection was primarily due to a lack of supporting documentary evidence and that the assessee deserved another opportunity to present its case. The impugned orders were set aside, and the matter was restored to the CIT(E) for fresh adjudication.

The Tribunal set aside the orders of the CIT(E) and restored the applications back to the CIT(E)'s file. The assessee was granted another opportunity to furnish the necessary documents and submissions.

The Tribunal found that the purchases were accounted for and reflected in the books of accounts. However, to minimize the rigor of reassessment, the assessee offered 10% over the profit on these purchases.

The Tribunal found that the issue required fresh examination by the Assessing Officer, considering the outstanding balances of trade creditors and the assessee's contention of accepted purchases. The Tribunal set aside the CIT(A)'s order and restored the matter to the AO for fresh adjudication.

The Tribunal held that the disallowance on commission expenses should be partly allowed as TDS was paid within the prescribed time and the AO did not consider the TDS returns. The disallowance of foreign travel expenses was upheld due to lack of established business nexus. The disallowance of business development expenses was allowed as the assessee provided details and similar expenses were allowed in the prior year.

The Tribunal found merit in the assessee's argument regarding insufficient opportunity. It set aside the CIT(E)'s order and restored the application for fresh adjudication, granting the assessee a reasonable opportunity to be heard.

The Tribunal upheld the CIT(A)'s decision to delete the disallowances of interest and commission. It reasoned that the entire loan amount was repaid, and the assessee had deducted TDS on interest, negating the basis for treating the transactions as accommodation entries.

The tribunal held that the CIT(E) did not provide adequate opportunity of being heard to the assessee, violating principles of natural justice. Therefore, the impugned order was set aside for fresh adjudication.

The Tribunal held that the assessee was justified in not deducting tax at source due to the interim directions from the Madras High Court, which stated that LFC payments would not be treated as income and no tax was to be deducted thereon.

The Tribunal held that the assessee was justified in not deducting tax at source due to the interim directions from the Madras High Court, which stated that LFC payments would not be treated as income and no tax was to be deducted thereon.

The Tribunal held that the reopening of the assessment was valid. However, it found that the CIT(A) erred in dismissing the appeal solely on delay without considering merits. The Tribunal set aside the matter to the AO for fresh consideration.

The Tribunal held that the interests of justice would be served by remanding the matter back to the Commissioner. The Commissioner is to reconsider the application afresh after taking into account the submissions and explanations provided by the assessee.

The Tribunal, considering the totality of facts and in the interest of justice, decided to remand the matter back to the Assessing Officer for a fresh assessment. The assessee was directed to submit all relevant documents and comply with notices.

The Tribunal held that the assessee was not granted sufficient opportunity and that the rejection was primarily due to a lack of documentary evidence. Therefore, the matter was restored to the CIT(E) for fresh adjudication, allowing the assessee to furnish all required documents and explanations.

The Tribunal held that rejecting the application after only one opportunity violated principles of natural justice. It was deemed appropriate to provide the assessee with another chance to present their case.

The Tribunal held that the assessee was not granted sufficient opportunity and that the rejection was primarily due to a lack of documentary evidence. Therefore, the matter was restored to the CIT(E) for fresh adjudication, allowing the assessee to furnish all required documents and explanations.

The Tribunal held that the rejection was primarily due to a lack of supporting documentary evidence and that the assessee deserved another opportunity to present its case. The impugned orders were set aside, and the matter was restored to the CIT(E) for fresh adjudication.

The Tribunal found that the CIT(A) failed to properly appreciate the facts and directions from the ITAT, specifically regarding the verification of TDS mismatch and the nature of agreements. Therefore, the matter was remanded back to the CIT(A) for fresh adjudication.

The Tribunal held that the assessee was justified in not deducting tax at source due to the interim directions from the Madras High Court, which stated that LFC payments would not be treated as income and no tax was to be deducted thereon.

The Tribunal held that the mere execution of an agreement to sell does not constitute a transfer under Section 2(47) unless possession or ownership rights are transferred. As the sale deed was executed in 2020, the capital gain was not taxable in the year under appeal.

The Tribunal held that the addition was unsustainable as the Revenue failed to provide evidence that the assessee was the owner or had received the entire sale consideration. The assessee had only declared and offered tax on their actual share of Rs. 20,20,202/-.

The Tribunal found that the assessee was non-compliant and failed to furnish requisite details. Therefore, the matter was remanded to the CIT(A) for fresh adjudication, allowing the assessee to submit all relevant documents.

The Tribunal held that the CIT(A) was justified in deleting the disallowance. The AO relied primarily on an untested statement without granting cross-examination and failed to provide independent corroborative evidence to prove the violation of Section 80IB(10)(f).

The Tribunal set aside the orders of the CIT(E) and restored the applications back to the CIT(E)'s file. The Assessee was granted another opportunity to furnish necessary documents and submissions, and the CIT(E) was directed to adjudicate afresh after providing a reasonable opportunity of being heard.

The Tribunal set aside the orders of the CIT(E) and restored the applications back to the CIT(E). The assessee was granted another opportunity to furnish necessary documents and submissions, and to be heard by the CIT(E).

The Tribunal held that the Assessing Officer failed to provide cogent evidence to prove the share transactions were bogus or arranged. The disallowance was based on suspicion and conjecture, and the documentary evidence produced by the assessee was not disproved by the Revenue.

The Tribunal held that the CIT(A) was justified in deleting the disallowance. The AO relied primarily on an untested statement without granting cross-examination and failed to provide independent corroborative evidence to prove the violation of Section 80IB(10)(f).

The Tribunal held that additions on account of alleged salary payments before July 2014 were to be deleted as there was no corroborative evidence. Additions related to unexplained bank credits were partly allowed, partly dismissed, and partly remitted back to the AO for further verification.

The Tribunal decided the issues as follows: Issue 1 (Undisclosed Salary Income): The Tribunal allowed the assessee's ground for AYs 2009-10 to 2013-14 and up to June 2014, directing deletion of additions. It reasoned that seized material indicated salary payments from July 2014 onwards, and additions before that date lacked corroborative evidence, violating the principle that search assessment additions must be based on seized material, not presumptions. However, for AYs 2014-15 (from July 2014) and 2015-16, the alleged salary was confirmed. Issue 2 (Unexplained Bank Credits - Rs.10,59,007/-): The Tribunal dismissed this ground as devoid of merits, implying it was confirmed against the assessee. Issue 3 (Unexplained Bank Credits - Rs.7,15,371/-): This ground was partly allowed. Additions of Rs.1,89,600/- and Rs.98,000/- as business income were confirmed. An addition of Rs.2,50,000/- and Rs.1110 was set aside to the AO for verification regarding its offer before the Settlement Commission. An addition of Rs.1205 was directed to be deleted, following an earlier year's order. Issue 4 (Foreign Travel Expenditure - Rs.2,02,518/-): This ground was partly allowed. The AO was directed to verify the claim that the expenditure was sponsored by the father-in-law and offered in a Settlement Application, and allow it if in accordance with law. Issue 5 (Unexplained Bank Credits - Rs.1,56,33,404/-): This ground was partly allowed. Additions of Rs.7,83,650/- and Rs.5,00,000/- as business income were confirmed. Additions related to Shree Ghamasha Co-op. Credit Society were remitted back to the AO for verification of offer before the Settlement Commission. A loan from Kailash Agrawal was remitted back to the AO for verification of bank statements. A loan from Neotech Education was deleted. A loan from Preet Patel was deleted, as the assessee discharged the onus under section 68. Operative Directions: Remand for verification in certain cases, deletion of additions in others, and confirmation of additions where justified. The ratio is that additions in search cases must be based on seized material, and the onus under section 68 can be discharged with proper documentation.

The Tribunal decided the issues as follows: Issue 1 (Undisclosed Salary Income): The Tribunal allowed the assessee's ground for AYs 2009-10 to 2013-14 and up to June 2014, directing deletion of additions. It reasoned that seized material indicated salary payments from July 2014 onwards, and additions before that date lacked corroborative evidence, violating the principle that search assessment additions must be based on seized material, not presumptions. However, for AYs 2014-15 (from July 2014) and 2015-16, the alleged salary was confirmed. Issue 2 (Unexplained Bank Credits - Rs.10,59,007/-): The Tribunal dismissed this ground as devoid of merits, implying it was confirmed against the assessee. Issue 3 (Unexplained Bank Credits - Rs.7,15,371/-): This ground was partly allowed. Additions of Rs.1,89,600/- and Rs.98,000/- as business income were confirmed. An addition of Rs.2,50,000/- and Rs.1110 was set aside to the AO for verification regarding its offer before the Settlement Commission. An addition of Rs.1205 was directed to be deleted, following an earlier year's order. Issue 4 (Foreign Travel Expenditure - Rs.2,02,518/-): This ground was partly allowed. The AO was directed to verify the claim that the expenditure was sponsored by the father-in-law and offered in a Settlement Application, and allow it if in accordance with law. Issue 5 (Unexplained Bank Credits - Rs.1,56,33,404/-): This ground was partly allowed. Additions of Rs.7,83,650/- and Rs.5,00,000/- as business income were confirmed. Additions related to Shree Ghamasha Co-op. Credit Society were remitted back to the AO for verification of offer before the Settlement Commission. A loan from Kailash Agrawal was remitted back to the AO for verification of bank statements. A loan from Neotech Education was deleted. A loan from Preet Patel was deleted, as the assessee discharged the onus under section 68. Operative Directions: Remand for verification in certain cases, deletion of additions in others, and confirmation of additions where justified. The ratio is that additions in search cases must be based on seized material, and the onus under section 68 can be discharged with proper documentation.

The Tribunal decided the issues as follows: Issue 1 (Undisclosed Salary Income): The Tribunal allowed the assessee's ground for AYs 2009-10 to 2013-14 and up to June 2014, directing deletion of additions. It reasoned that seized material indicated salary payments from July 2014 onwards, and additions before that date lacked corroborative evidence, violating the principle that search assessment additions must be based on seized material, not presumptions. However, for AYs 2014-15 (from July 2014) and 2015-16, the alleged salary was confirmed. Issue 2 (Unexplained Bank Credits - Rs.10,59,007/-): The Tribunal dismissed this ground as devoid of merits, implying it was confirmed against the assessee. Issue 3 (Unexplained Bank Credits - Rs.7,15,371/-): This ground was partly allowed. Additions of Rs.1,89,600/- and Rs.98,000/- as business income were confirmed. An addition of Rs.2,50,000/- and Rs.1110 was set aside to the AO for verification regarding its offer before the Settlement Commission. An addition of Rs.1205 was directed to be deleted, following an earlier year's order. Issue 4 (Foreign Travel Expenditure - Rs.2,02,518/-): This ground was partly allowed. The AO was directed to verify the claim that the expenditure was sponsored by the father-in-law and offered in a Settlement Application, and allow it if in accordance with law. Issue 5 (Unexplained Bank Credits - Rs.1,56,33,404/-): This ground was partly allowed. Additions of Rs.7,83,650/- and Rs.5,00,000/- as business income were confirmed. Additions related to Shree Ghamasha Co-op. Credit Society were remitted back to the AO for verification of offer before the Settlement Commission. A loan from Kailash Agrawal was remitted back to the AO for verification of bank statements. A loan from Neotech Education was deleted. A loan from Preet Patel was deleted, as the assessee discharged the onus under section 68. Operative Directions: Remand for verification in certain cases, deletion of additions in others, and confirmation of additions where justified. The ratio is that additions in search cases must be based on seized material, and the onus under section 68 can be discharged with proper documentation.

The Tribunal set aside the orders of the CIT(E) and restored the applications back to the CIT(E)'s file. The Assessee was granted another opportunity to furnish necessary documents and submissions, and the CIT(E) was directed to adjudicate afresh after providing a reasonable opportunity of being heard.

The Tribunal decided the issues as follows: Issue 1 (Undisclosed Salary Income): The Tribunal allowed the assessee's ground for AYs 2009-10 to 2013-14 and up to June 2014, directing deletion of additions. It reasoned that seized material indicated salary payments from July 2014 onwards, and additions before that date lacked corroborative evidence, violating the principle that search assessment additions must be based on seized material, not presumptions. However, for AYs 2014-15 (from July 2014) and 2015-16, the alleged salary was confirmed. Issue 2 (Unexplained Bank Credits - Rs.10,59,007/-): The Tribunal dismissed this ground as devoid of merits, implying it was confirmed against the assessee. Issue 3 (Unexplained Bank Credits - Rs.7,15,371/-): This ground was partly allowed. Additions of Rs.1,89,600/- and Rs.98,000/- as business income were confirmed. An addition of Rs.2,50,000/- and Rs.1110 was set aside to the AO for verification regarding its offer before the Settlement Commission. An addition of Rs.1205 was directed to be deleted, following an earlier year's order. Issue 4 (Foreign Travel Expenditure - Rs.2,02,518/-): This ground was partly allowed. The AO was directed to verify the claim that the expenditure was sponsored by the father-in-law and offered in a Settlement Application, and allow it if in accordance with law. Issue 5 (Unexplained Bank Credits - Rs.1,56,33,404/-): This ground was partly allowed. Additions of Rs.7,83,650/- and Rs.5,00,000/- as business income were confirmed. Additions related to Shree Ghamasha Co-op. Credit Society were remitted back to the AO for verification of offer before the Settlement Commission. A loan from Kailash Agrawal was remitted back to the AO for verification of bank statements. A loan from Neotech Education was deleted. A loan from Preet Patel was deleted, as the assessee discharged the onus under section 68. Operative Directions: Remand for verification in certain cases, deletion of additions in others, and confirmation of additions where justified. The ratio is that additions in search cases must be based on seized material, and the onus under section 68 can be discharged with proper documentation.

The Tribunal decided the issues as follows: Issue 1 (Undisclosed Salary Income): The Tribunal allowed the assessee's ground for AYs 2009-10 to 2013-14 and up to June 2014, directing deletion of additions. It reasoned that seized material indicated salary payments from July 2014 onwards, and additions before that date lacked corroborative evidence, violating the principle that search assessment additions must be based on seized material, not presumptions. However, for AYs 2014-15 (from July 2014) and 2015-16, the alleged salary was confirmed. Issue 2 (Unexplained Bank Credits - Rs.10,59,007/-): The Tribunal dismissed this ground as devoid of merits, implying it was confirmed against the assessee. Issue 3 (Unexplained Bank Credits - Rs.7,15,371/-): This ground was partly allowed. Additions of Rs.1,89,600/- and Rs.98,000/- as business income were confirmed. An addition of Rs.2,50,000/- and Rs.1110 was set aside to the AO for verification regarding its offer before the Settlement Commission. An addition of Rs.1205 was directed to be deleted, following an earlier year's order. Issue 4 (Foreign Travel Expenditure - Rs.2,02,518/-): This ground was partly allowed. The AO was directed to verify the claim that the expenditure was sponsored by the father-in-law and offered in a Settlement Application, and allow it if in accordance with law. Issue 5 (Unexplained Bank Credits - Rs.1,56,33,404/-): This ground was partly allowed. Additions of Rs.7,83,650/- and Rs.5,00,000/- as business income were confirmed. Additions related to Shree Ghamasha Co-op. Credit Society were remitted back to the AO for verification of offer before the Settlement Commission. A loan from Kailash Agrawal was remitted back to the AO for verification of bank statements. A loan from Neotech Education was deleted. A loan from Preet Patel was deleted, as the assessee discharged the onus under section 68. Operative Directions: Remand for verification in certain cases, deletion of additions in others, and confirmation of additions where justified. The ratio is that additions in search cases must be based on seized material, and the onus under section 68 can be discharged with proper documentation.

The Tribunal decided the issues as follows: Issue 1 (Undisclosed Salary Income): The Tribunal allowed the assessee's ground for AYs 2009-10 to 2013-14 and up to June 2014, directing deletion of additions. It reasoned that seized material indicated salary payments from July 2014 onwards, and additions before that date lacked corroborative evidence, violating the principle that search assessment additions must be based on seized material, not presumptions. However, for AYs 2014-15 (from July 2014) and 2015-16, the alleged salary was confirmed. Issue 2 (Unexplained Bank Credits - Rs.10,59,007/-): The Tribunal dismissed this ground as devoid of merits, implying it was confirmed against the assessee. Issue 3 (Unexplained Bank Credits - Rs.7,15,371/-): This ground was partly allowed. Additions of Rs.1,89,600/- and Rs.98,000/- as business income were confirmed. An addition of Rs.2,50,000/- and Rs.1110 was set aside to the AO for verification regarding its offer before the Settlement Commission. An addition of Rs.1205 was directed to be deleted, following an earlier year's order. Issue 4 (Foreign Travel Expenditure - Rs.2,02,518/-): This ground was partly allowed. The AO was directed to verify the claim that the expenditure was sponsored by the father-in-law and offered in a Settlement Application, and allow it if in accordance with law. Issue 5 (Unexplained Bank Credits - Rs.1,56,33,404/-): This ground was partly allowed. Additions of Rs.7,83,650/- and Rs.5,00,000/- as business income were confirmed. Additions related to Shree Ghamasha Co-op. Credit Society were remitted back to the AO for verification of offer before the Settlement Commission. A loan from Kailash Agrawal was remitted back to the AO for verification of bank statements. A loan from Neotech Education was deleted. A loan from Preet Patel was deleted, as the assessee discharged the onus under section 68. Operative Directions: Remand for verification in certain cases, deletion of additions in others, and confirmation of additions where justified. The ratio is that additions in search cases must be based on seized material, and the onus under section 68 can be discharged with proper documentation.

The Tribunal held that while the AO's action of treating the entire credit entries as income was incorrect, the assessee's plea of non-receipt of notices was not entirely valid due to previous adjournments and the email ID used being in the department's database. The matter was set aside to the CIT(A) for fresh adjudication.

The Tribunal set aside the orders of the CIT(E) and restored the applications back to the CIT(E). The assessee was granted another opportunity to furnish necessary documents and submissions, and to be heard by the CIT(E).

The Tribunal held that the donation to the political party was bogus, based on extensive investigation material and statements from individuals admitting to a bogus donation scam. The Tribunal found that the political party was not filing contribution reports and was being used as a vehicle for accommodation entries.

The Tribunal found that the assessee was not given a proper opportunity to present their case. Therefore, the impugned orders were set aside, and the matter was restored to the CIT(E) for fresh consideration.