ITAT Ahmedabad Judgments — June 2026

The Tribunal held that the interests of justice would be served by giving the assessee an opportunity to present its case. The impugned orders were set aside, and the matter was restored to the CIT(E) for a fresh decision.

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 a fresh decision.

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 a fresh decision.

The Tribunal found that the interests of justice would be served by allowing the assessee an opportunity to present its case. Therefore, the impugned orders were set aside, and the matter was restored to the CIT(E) for a fresh decision.

The Tribunal found that the interests of justice would be served by allowing the assessee an opportunity to present its case. Therefore, the impugned orders were set aside, and the matter was restored to the CIT(E) for a fresh decision.

The Tribunal held that the CIT(A) erred in not condoning the delay and not adjudicating the grounds on merits. The Tribunal set aside the matter to the CIT(A) to condone the delay and decide the appeals on merits.

The Tribunal held that the CIT(A) erred in not condoning the delay and adjudicating the appeal on merits. The Tribunal set aside the matter to the CIT(A) to condone the delay and decide the grounds on merit, including penalty appeals.

The Tribunal held that the CIT(A) erred in not condoning the delay and adjudicating the appeal on merits. The Tribunal set aside the matter to the CIT(A) to condone the delay and decide the grounds on merit, including penalty appeals.

The Tribunal held that additions based on incomplete promissory notes and images without corroborative evidence were not sustainable. It also found that a land transaction did not materialize, and therefore, no income could be added to the assessee's account.

The Tribunal held that additions based on incomplete promissory notes and images without corroborative evidence were not sustainable. It also found that a land transaction did not materialize, and therefore, no income could be added to the assessee's account.

The Tribunal held that the assessee's relinquishment of his right in a house property for Rs. 7,51,000/- paid in cash by his brother, supported by an unregistered sale deed, explained the source of a portion of the cash deposit. Therefore, the addition to that extent was not sustainable.

The Tribunal held that the assessee had provided sufficient documentation, including confirmations from farmers who provided loans, and cash book entries, to explain the cash deposits and credits. The AO's additions were based on conjecture and failed to consider the provided evidence.

The Tribunal held that for the addition of Rs.48,00,000/- on account of unexplained unsecured loans (Issue 1), the CIT(A) was correct in deleting the addition. The promissory notes were found to be incomplete and inconclusive, lacking essential details like the lender's name, and there was no corroborative evidence to establish that cash loans were actually received. The Tribunal agreed that these could be treated as dump documents. Regarding the addition of Rs.1,00,00,000/- for unexplained investment in land (Issue 2), the Tribunal upheld the CIT(A)'s deletion. It was noted that the assessee was neither the buyer nor the seller, the property was under litigation, and the deal did not materialize. The assessee acted as a broker, and even if a token payment was indicated, it could not be treated as the assessee's income. For the addition of Rs.3,16,14,625/- on account of unaccounted cash receipt from land sale (Issue 3), the Tribunal confirmed the CIT(A)'s deletion. The property remained in the names of co-owners, and the sale transaction did not materialize as one co-owner refused to sell. No registered sale deed, agreement to sell, or other evidence of transfer was produced by the Revenue. The addition was based solely on electronic notings without independent corroborative evidence of completion of the transaction or receipt of cash. The Tribunal found no infirmity in the CIT(A)'s order.

The Tribunal held that for the addition of Rs.48,00,000/- on account of unexplained unsecured loans (Issue 1), the CIT(A) was correct in deleting the addition. The promissory notes were found to be incomplete and inconclusive, lacking essential details like the lender's name, and there was no corroborative evidence to establish that cash loans were actually received. The Tribunal agreed that these could be treated as dump documents. Regarding the addition of Rs.1,00,00,000/- for unexplained investment in land (Issue 2), the Tribunal upheld the CIT(A)'s deletion. It was noted that the assessee was neither the buyer nor the seller, the property was under litigation, and the deal did not materialize. The assessee acted as a broker, and even if a token payment was indicated, it could not be treated as the assessee's income. For the addition of Rs.3,16,14,625/- on account of unaccounted cash receipt from land sale (Issue 3), the Tribunal confirmed the CIT(A)'s deletion. The property remained in the names of co-owners, and the sale transaction did not materialize as one co-owner refused to sell. No registered sale deed, agreement to sell, or other evidence of transfer was produced by the Revenue. The addition was based solely on electronic notings without independent corroborative evidence of completion of the transaction or receipt of cash. The Tribunal found no infirmity in the CIT(A)'s order.

The Tribunal held that the CIT(A) failed to consider the assessee's explanation regarding cash brought from foreign exchange during prior visits to India. The Tribunal found the addition made by the AO to be unjustified.

The Tribunal held that the amounts received from the assessee's wife and father were genuine. The assessee had provided sufficient documentary evidence, including bank statements and confirmations, to substantiate the transactions.

The Tribunal held that the addition for unexplained jewellery in the assessee's hands was covered by disclosures made by other family members, thus amounting to double taxation. For the unexplained cash, the Tribunal allowed a set-off to the extent of the balance of income disclosed by the assessee's husband.

The Tribunal held that the CIT(E) rejected the application without providing the assessee an opportunity to be heard, violating the principles of natural justice. Therefore, the order was set aside for fresh adjudication.

The ITAT condoned the delay in filing the appeal, citing the assessee's explanation and the need to decide meritorious cases. The Tribunal set aside the matter to the AO for fresh adjudication, subject to the assessee paying a cost.

The Tribunal noted that accepting old denomination notes was permitted for consumer co-operative societies. However, the assessee failed to adequately correlate the cash deposits with its sales. Therefore, the matter was set aside to the AO for further examination.

The Tribunal held that the addition for unexplained jewellery in the assessee's hands was covered by disclosures made by other family members, thus amounting to double taxation. For the unexplained cash, the Tribunal allowed a set-off to the extent of the balance of income disclosed by the assessee's husband.

The Tribunal held that the disallowance was not justified as the seller had passed away, leading to the closure of his business and subsequent GST cancellation. The assessee had provided ample evidence of the genuine nature of the transactions.

The Tribunal held that the addition was not justified as the assessee provided sales invoices, delivery challans, VAT/GST records, and bank statements, and the transactions were through banking channels. The Assessing Officer made the addition based on suspicion and conjecture without rejecting the assessee's books of account.