ITAT Ahmedabad Judgments — August 2026

MUKESH ROSHANLAL SHAH,AHMEDABAD vs DCIT, CIRCLE 1(1)(1), AHMEDABAD, AHMEDABAD

ITA 2241/AHD/2026[2020-21]Status: Disposed31 Aug 2026AY 2020-21Partly Allowed

The Tribunal set aside the assessment order to allow the assessee an opportunity to present evidence and explanations to the Assessing Officer. The penalty under Section 271AAC(1) was deleted as it was consequential to the assessment, while the penalty under Section 272A(1)(d) was confirmed.

MUKESH ROSHANLAL SHAH,AHMEDABAD vs DCIT, CIRCLE 1(1)(1), AHMEDABAD, AHMEDABAD

ITA 2240/AHD/2026[2020-21]Status: Disposed31 Aug 2026AY 2020-21Partly Allowed

The Tribunal set aside the assessment order to allow the assessee an opportunity to present evidence and explanations to the Assessing Officer. The penalty under Section 271AAC(1) was deleted as it was consequential to the assessment, while the penalty under Section 272A(1)(d) was confirmed.

NAEEM SIRAJUDDIN TIRMIZI,AHMEDABAD vs PCIT (CENTRAL), AHMEDABAD, AHMEDABAD

ITA 2114/AHD/2026[2021-22]Status: Disposed31 Aug 2026AY 2021-22Allowed

The Tribunal held that the PCIT's revision order was without jurisdiction. This was because the Assessing Officer did not have the authority to initiate penalty proceedings under Section 271D for assessment years prior to April 1, 2025, as per the Gujarat High Court's ruling in Dilip Patel vs. PCIT.

NAEEM SIRAJUDDIN TIRMIZI,AHMEDABAD vs PCIT (CENTRAL), AHMEDABAD, AHMEDABAD

ITA 2111/AHD/2026[2017-18]Status: Disposed31 Aug 2026AY 2017-18Allowed

The Tribunal held that the PCIT's revision order was without jurisdiction. This was because the Assessing Officer did not have the authority to initiate penalty proceedings under Section 271D for assessment years prior to April 1, 2025, as per the Gujarat High Court's ruling in Dilip Patel vs. PCIT.

NAEEM SIRAJUDDIN TIRMIZI,AHMEDABAD vs PCIT (CENTRAL), AHMEDABAD, AHMEDABAD

ITA 2110/AHD/2026[2016-17]Status: Disposed31 Aug 2026AY 2016-17Allowed

The Tribunal held that the PCIT's revision order was without jurisdiction. This was because the Assessing Officer did not have the authority to initiate penalty proceedings under Section 271D for assessment years prior to April 1, 2025, as per the Gujarat High Court's ruling in Dilip Patel vs. PCIT.

MUKESH ROSHANLAL SHAH,AHMEDABAD vs DCIT, CIRCLE 1(1)(1), AHMEDABAD, AHMEDABAD

ITA 2242/AHD/2026[2020-21]Status: Disposed31 Aug 2026AY 2020-21Partly Allowed

The Tribunal set aside the assessment order to allow the assessee an opportunity to present evidence and explanations to the Assessing Officer. The penalty under Section 271AAC(1) was deleted as it was consequential to the assessment, while the penalty under Section 272A(1)(d) was confirmed.

NAEEM SIRAJUDDIN TIRMIZI,AHMEDABAD vs PCIT (CENTRAL), AHMEDABAD, AHMEDABAD

ITA 2109/AHD/2026[2015-16]Status: Disposed31 Aug 2026AY 2015-16Allowed

The Tribunal held that the PCIT's revision order was without jurisdiction. This was because the Assessing Officer did not have the authority to initiate penalty proceedings under Section 271D for assessment years prior to April 1, 2025, as per the Gujarat High Court's ruling in Dilip Patel vs. PCIT.

SHRI KABIRPANTHI GADI ,GUJARAT vs INCOME TAX WARD-2 EXEPMTION, GUJARAT

ITA 1535/AHD/2026[2019-20]Status: Disposed31 Aug 2026AY 2019-20Allowed

The Tribunal condoned the delay in filing the appeal, considering the technical nature of the disallowance and the circumstances of ignorance and death of the accountant. The matter was restored to the AO for adjudication on merits.

LIMKHEDA VIBHAG YUVAK EDUCATION,DAHOD vs THE ITO, WARD-EXEMPTION, VADODARA

ITA 2299/AHD/2026[2019-20]Status: Disposed31 Aug 2026AY 2019-20Remanded

The Tribunal set aside the CIT(A)'s order, granting the assessee another opportunity to present its case and evidence on merits. The delay in filing the appeal was condoned.

NAEEM SIRAJUDDIN TIRMIZI,AHMEDABAD vs PCIT (CENTRAL), AHMEDABAD, AHMEDABAD

ITA 2113/AHD/2026[2019-20]Status: Disposed31 Aug 2026AY 2019-20Allowed

The Tribunal held that the PCIT's revision order was without jurisdiction. This was because the Assessing Officer did not have the authority to initiate penalty proceedings under Section 271D for assessment years prior to April 1, 2025, as per the Gujarat High Court's ruling in Dilip Patel vs. PCIT.

ITO, WARD-1, PATAN vs PRADIPBHAI DINESHCHANDRA THAKKAR, PATAN

ITA 1566/AHD/2026[2018-19]Status: Disposed31 Aug 2026AY 2018-19Remanded

The Tribunal found that the CIT(A) had admitted additional evidence without obtaining a remand report from the Assessing Officer, violating Rule 46A. Therefore, the matter was restored to the Assessing Officer for fresh assessment.

NAEEM SIRAJUDDIN TIRMIZI,AHMEDABAD vs PCIT (CENTRAL), AHMEDABAD, AHMEDABAD

ITA 2112/AHD/2026[2018-19]Status: Disposed31 Aug 2026AY 2018-19Allowed

The Tribunal held that the PCIT's revision order was without jurisdiction. This was because the Assessing Officer had no jurisdiction to initiate penalty proceedings under Section 271D for assessment years prior to April 1, 2025, as per the Gujarat High Court's ruling in Dilip Patel's case.

NAEEM SIRAJUDDIN TIRMIZI,AHMEDABAD vs PCIT (CENTRAL), AHMEDABAD, AHMEDABAD

ITA 2108/AHD/2026[2014-15]Status: Disposed31 Aug 2026AY 2014-15Allowed

The Tribunal held that the PCIT's revision order was without jurisdiction. This was because the Assessing Officer did not have the authority to initiate penalty proceedings under Section 271D for assessment years prior to April 1, 2025, as per the Gujarat High Court's ruling in Dilip Patel vs. PCIT.

MITESH SHAH,AHMEDABAD vs ITO, WARD 1(2)(3), AHMEDABAD, AHMEDABAD

ITA 1304/AHD/2026[2019-20]Status: Disposed25 Aug 2026AY 2019-20Allowed

The Tribunal held that Section 37 is appropriate for non-genuine purchases where the source of expenditure is explained, while Section 69C applies when the source itself is unexplained. The AO's view was plausible and legally tenable.

STATE BANK OF INDIA LCPC,BHAVNAGAR vs THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE (TDS), AHMEDABAD, AHEMDABAD

ITA 1847/AHD/2026[2016-17]Status: Disposed25 Aug 2026AY 2016-17Allowed

The Tribunal held that the assessee bank could not be treated as an assessee in default because it was bound to comply with the interim directions of the Madras High Court, which prevented TDS deduction. Therefore, the demands under Section 201(1) and 201(1A) were set aside.

BARODA DISTRICT COOPERATIVE MILK PRODUCERS UNION LIMITED,VADODARA, GUJARAT vs ASST. COMMISSIONER OF INCOME TAX OFFICER, CIRCLE 1(1)(1), VADODARA, VADODARA, GUJARAT

ITA 417/AHD/2025[2022-23]Status: Disposed25 Aug 2026AY 2022-23Partly Allowed

The Tribunal held that the assessee was entitled to claim deduction under Section 80P(2)(d) on the gross income earned, following previous ITAT decisions. The disallowance under Section 14A was also deleted based on favorable case law.

STATE BANK OF INDIA RACPC BRANCH,VADODARA vs THE INCOME TAX OFFICER, TDS CIRCLE TDS, VADODARA, VADODARA

ITA 1817/AHD/2026[2017-18]Status: Disposed25 Aug 2026AY 2017-18Allowed

The Tribunal held that the assessee bank could not be treated as an assessee in default because it was bound to comply with the interim directions of the Madras High Court, which prevented TDS deduction. Therefore, the demands under Section 201(1) and 201(1A) were set aside.

SWARAJ CORPORATION,ANAND vs THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

ITA 1051/AHD/2026[2015-16]Status: Disposed25 Aug 2026AY 2015-16Remanded

The Tribunal held that expenses incurred between setting up a business and its commencement are generally deductible. However, due to insufficient evidence regarding the nature of expenses, commencement of business, revenue recognition, and utilization of borrowed funds, the matter was restored to the CIT(A) for fresh adjudication.

PRAVINKUMAR RAMJIBHAI PATEL,GUJARAT vs ITO WARD 1, MEHSANA, MEHSANA

ITA 2312/AHD/2026[2021-22]Status: Disposed25 Aug 2026AY 2021-22Allowed

The Tribunal held that compensation received under the BSNL VRS-2019 scheme is eligible for exemption under Section 10(10B) of the Income Tax Act, following the decisions of coordinate benches. The assessee is entitled to this exemption.

MAYANK GUNVANTRAY JOSHI,AHMEDABAD vs INCOME TAX OFFICER, AHMEDABAD

ITA 1471/AHD/2026[2021-22]Status: Disposed25 Aug 2026AY 2021-22Allowed

The Tribunal condoned the delay in filing the appeals, holding that the compensation received under BSNL VRS-2019 is exempt under Section 10(10B) of the Act. The Assessing Officer was directed to recompute the taxable income and grant the refund accordingly.

STATE BANK OF INDIA MANEK BAUG BRANCH (08052),AHMEDABAD vs THE JOINT COMMISSIONER OF INCOME TAX, TDS ADDL/JT CIT TDS AHM, AHMEDABAD

ITA 1818/AHD/2026[2017-18]Status: Disposed25 Aug 2026AY 2017-18Allowed

The Tribunal held that the assessee bank could not be treated as an assessee in default because it was bound to comply with the interim directions of the Madras High Court, which prevented TDS deduction. Therefore, the demands under Section 201(1) and 201(1A) were set aside.

RAMESHBHAI CHHOTABHAI VANKAR,PETLAD vs INCOME TAX OFFICER, PETLAD

ITA 1838/AHD/2026[2021-22]Status: Disposed25 Aug 2026AY 2021-22Allowed

The Tribunal held that the compensation received under the BSNL VRS-2019 scheme is eligible for exemption under Section 10(10B) of the Income Tax Act. The delay in filing the appeal was condoned, and the assessee was granted the exemption.

MAYANK GUNVANTRAY JOSHI,AHMEDABAD vs INCOME TAX OFFICER, AHMEDABAD

ITA 1470/AHD/2026[2020-2021]Status: Disposed25 Aug 2026AY 2020-2021Allowed

The Tribunal condoned the delay in filing the appeals, holding that the compensation received under BSNL VRS-2019 is exempt under Section 10(10B) of the Act. The Assessing Officer was directed to recompute the taxable income and grant the refund accordingly.

RAAMA ENTERPRISES,VADODARA vs ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(3), VADODARA, VADODARA

ITA 899/AHD/2026[2017-18]Status: Disposed25 Aug 2026AY 2017-18Allowed

The Tribunal held that the surrendered amount represented business receipts from the assessee's existing business and not unexplained cash credits. Therefore, the addition under Section 68 and the consequent taxation under Section 115BBE were not justified.

STATE BANK OF INDIA LCPC,BHAVNAGAR vs THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE (TDS), AHMEDABAD, AHMEDABAD

ITA 1848/AHD/2026[2017-18]Status: Disposed25 Aug 2026AY 2017-18Allowed

The Tribunal held that the assessee bank could not be treated as an assessee in default because it was bound to comply with the interim directions of the Madras High Court, which prevented TDS deduction. Therefore, the demands under Section 201(1) and 201(1A) were set aside.

SHREE UMIYA KHAKHARIYA VADHIYAR CHUVAL EDUCATION TRUST,AHMEDABAD vs CIT(EXEMPTION), AHMEDABAD, ANANDNAGAR

ITA 2381/AHD/2026[NA]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

SIDDHIVINAYAK EDUCATION TRUST,PATAN vs COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD, AHMEDABAD

ITA 1866/AHD/2026[N.A.]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

SHREE MOTA HANUMAN DAADA SEVA TRUST,KAPADVANJ vs THE CIT(EXEMPTION), AHMEDABAD

ITA 1371/AHD/2026[NA]Status: Disposed24 Aug 2026Remanded

The Tribunal condoned the delay in filing the appeal and set aside the CIT(E)'s order. The CIT(E) was directed to either treat the application under the correct sub-provision or allow the assessee to file a rectified application, and then decide on merits after providing an opportunity to be heard.

SRISTI INNOVATIONS,AHMEDABAD vs COMMISSIONER OF INCOME TAX(EXEMPTION),AHMEDABAD, AHMEDABD

ITA 1853/AHD/2026[NOT APPLICABLE]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

SWAPATH TRUST,AHMEDABAD vs COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD, AHMEDABAD

ITA 1724/AHD/2026[NA]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

SHREE UMIYA KHAKHARIYA VADHIYAR CHUVAL EDUCATION TRUST ,AHMEDABAD vs CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

ITA 2380/AHD/2026[NA]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

HEENA VIPIN NAIR,NARANPURA vs THE INCOME TAX OFFICER,WARD 7(2)(1), VEJALPUR

ITA 1424/AHD/2026[2020-21]Status: Disposed24 Aug 2026AY 2020-21Allowed

The Tribunal held that the compensation received under BSNL VRS-2019 is exempt under Section 10(10B). The Assessing Officer was directed to grant the refund due, and the exemption under Section 10(10C) was withdrawn to avoid double exemption.

GOKULESH FUEL STATION,KANERA vs THE DY.CIT, ANAND CIRCLE, ANAND CIRCLE

ITA 1192/AHD/2026[2018-2019]Status: Disposed24 Aug 2026AY 2018-2019Allowed

The Tribunal held that taxpayers should not be punished for bonafide mistakes and directed the Assessing Officer to verify the payment. If payment was made before the due date, no disallowance under Section 43B should be made.

SHRI SADGURUDHAM NIRLOBHI ASHRAM,BHARUCH vs CIT (EXEMPTION), AHMEDABAD

ITA 1696/AHD/2026[NA]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

SPECTRUM CHARITABLE FOUNDATION TRUST,AHMEDABAD vs COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD, AHMEDABAD

ITA 1757/AHD/2026[N.A.]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

VIDHYA ARAMBH CHARITABLE TRUST,GUJARAT vs CIT (EXEMPTION), AHMEDABAD, GUJARAT

ITA 1989/AHD/2026[N.A.]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

ENDEL RETAIL AND CUSTOMER CARE PRIVATE LIMITED,AMBAWADI, AHMEDABAD vs DEPUTY COMMISSIONER OF INCOME TAX, VEJALPUR, AHMEDABAD

ITA 1204/AHD/2026[2023-24]Status: Disposed24 Aug 2026AY 2023-24Allowed

The Tribunal allowed the appeal, following a previous order where it was held that delay in filing Form 67 should not prejudice the assessee's right to claim FTC, especially when taxes have been paid both in India and abroad. The Tribunal directed the revenue to grant the FTC.

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs SHAPOORJI PALLONJI INFRASTRUCTURE GUJARAT PRIVATE LIMITED, VADODARA

ITA 1510/AHD/2025[2016-17]Status: Disposed24 Aug 2026AY 2016-17Remanded

The Tribunal found that the assessee failed to establish the genuineness of share capital transactions involving circular rotation of funds. Consequently, the matter was restored to the AO for fresh examination.

POLYCOAT ELECTRA SERVICES (INDIA) PRIVATE LIMITED,AHMEDABAD vs THE DCIT, CIRCLE-3(1)(1), AHMEDABAD

ITA 2301/AHD/2026[2015-16]Status: Disposed24 Aug 2026AY 2015-16Partly Allowed

The Tribunal held that the notice under Section 148 for AY 2015-2016, issued after 31.03.2021, was invalid based on Supreme Court and Gujarat High Court judgments. Consequently, the reassessment proceedings and the assessment order were quashed.

VALKA EDUCATION AND CHARITABLE TRUST,AHMEDABAD vs CIT (EXEMPTION), AHMEDABAD, AHMEDABAD

ITA 1993/AHD/2026[NA]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

SWAPATH TRUST,AHMEDABAD vs COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD, AHMEDABAD

ITA 1725/AHD/2026[NA]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

HEENA VIPIN NAIR,NARANPURA vs THE INCOME TAX OFFICER, WARD 7(2)(1), VEJALPUR

ITA 1425/AHD/2026[21-22]Status: Disposed24 Aug 2026Allowed

The Tribunal held that the compensation received under BSNL VRS-2019 is exempt under Section 10(10B). The Assessing Officer was directed to grant the refund and compute taxable income accordingly.

JUPITER COMTEX PRIVATE LIMITED,VATVA vs ASST. CIT CIRCLE 2(1)(1), VEJALPUR

ITA 1823/AHD/2026[2012-13]Status: Disposed24 Aug 2026AY 2012-13Allowed

The Tribunal held that commission paid to non-resident agents for services rendered outside India is not chargeable to tax in India. Therefore, the assessee was not liable to deduct TDS, and the disallowance under Section 40(a)(i) was not warranted.

VIKAS CHARITABLE TRUST,KHEDA vs THE CIT(EXEMPTION), AHMEDABAD

ITA 1636/AHD/2026[NA]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

S K LOGISTICS,ASHRAM ROAD, AHMEDABAD vs INCOME TAX OFFICER, WARD-1(1)(3), VEJALPUR, AHMEDABAD

ITA 1790/AHD/2025[2023-24]Status: Disposed24 Aug 2026AY 2023-24Allowed

The Tribunal held that the addition was based on a clerical mistake in party-wise purchase details, and the assessee had provided sufficient documentary evidence to rectify the error. The Assessing Officer and CIT(A) rejected these documents without independent verification.

SHREE ANNAPURNADHAM TRUST,GANDHINAGAR vs CIT(EXEMPTION) AHMEDABAD, AHMEDABAD

ITA 1720/AHD/2026[2026-2027]Status: Disposed24 Aug 2026AY 2026-2027Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

VIKAS CHARITABLE TRUST,KHEDA vs THE CIT(EXEMPTION), AHMEDABAD

ITA 1637/AHD/2026[NA]Status: Disposed24 Aug 2026Remanded

The Tribunal held that both parties failed to discharge their responsibilities, leading to unintended consequences for genuine charitable activities. To serve the interest of justice, the Tribunal set aside the rejection orders and remanded the matters back to the CIT(E) for fresh adjudication.

SHREE FOFARIA FAMILY CHARITABLE TRUST,79, VISHWAS COLONY, ALKAPURI, ALKAPURI S.O, VADODA vs CIT (EXEMPTION), AHMEDABAD

ITA 1073/AHD/2026[2025-26]Status: Disposed21 Aug 2026AY 2025-26Remanded

The Tribunal held that the rejection was based on a technical defect without examining the merits and without affording the assessee an opportunity to explain the inadvertent mistake. Therefore, the impugned order was set aside.

DCIT CENTRAL CIRCLE-2(2), AHMEDABAD vs NIRMA LIMITED, AHMEDABAD

ITA 1570/AHD/2026[2020-21]Status: Disposed21 Aug 2026AY 2020-21Dismissed

The Tribunal upheld the CIT(A)'s decision, relying on previous ITAT rulings and High Court judgments. It was held that depreciation on goodwill arising from amalgamation is allowable, and that external market comparables are valid benchmarks for determining the ALP of inter-unit sales of electricity and steam, even if steam is a by-product.

SWAMINARAYAN MANDIR ,SWAMINARAYAN MANDIR vs CIT(EXEMPTION), CIT(EXEMPTION)

ITA 1681/AHD/2026[NA]Status: Disposed21 Aug 2026Partly Allowed

The Tribunal condoned the delay in filing the appeal and set aside the CIT(E)'s order. It directed the CIT(E) to either treat the application as filed under the correct sub-provision or allow the assessee to file a rectified application, with an opportunity to be heard.