ITAT Ahmedabad Judgments — August 2026

The Tribunal upheld the CIT(A)'s order, finding that the issue regarding the apportionment of contributions under Section 35(1)(ii) for Section 80IA deduction had already been decided in favor of the assessee by a coordinate bench. The AO's disallowances were found to be covered by this earlier decision.

The Tribunal upheld the CIT(A)'s decision to delete additions related to unsecured loans, loan repayment, cash deposits, and bad debts, finding that the assessee had provided sufficient evidence. The Tribunal also upheld the reduction in disallowance for purchases and expenses.

The Tribunal upheld the CIT(A)'s order, finding that the issue regarding the apportionment of contributions under Section 35(1)(ii) for Section 80IA deduction had already been decided in favor of the assessee by a coordinate bench. The AO's disallowances were found to be covered by this earlier decision.

The Tribunal held that the Assessing Officer's addition was based on mere presumption and not on material facts, as the share transactions were conducted through a broker on the stock exchange and reflected in the demat account. The assessee was not liable for alleged manipulation by brokers when transactions were through banking channels.

The Tribunal upheld the decision of the CIT(A) that the reassessment order was time-barred as it was passed beyond the period prescribed under Section 153 of the Income-tax Act. Consequently, the addition made in the reassessment order was quashed.

The Tribunal held that the CIT(A) did not properly examine the conditions for the existence of a PE under Article 5 of the India-UK DTAA. Therefore, the matter was set aside to the AO to verify the existence of a PE and decide the disallowance accordingly.

The Tribunal held that the Completion Certificate alone is not conclusive proof of project completion and that subsequent expenditure incurred by the assessee was not disputed. The AO's recomputation was based on an alternative working, not on any defect in the books or suppression of income.

The CIT(A) held that the cash deposits were from regular business sales and not unexplained income. The Tribunal found no infirmity in the CIT(A)'s order and upheld it.

The Tribunal found that the assessee had provided explanations and evidence regarding the source of cash deposits and credit entries, which were not properly considered by the lower authorities. Therefore, the matter was set aside to the CIT(A) for fresh adjudication.

The Tribunal held that the assessee banks cannot be treated as assessees in default under Section 201(1) of the Income Tax Act because they were legally bound to comply with the interim judicial directions. Consequently, the interest charged under Section 201(1A) was also set aside.

The tribunal held that the assessee cannot be penalized for claiming the deduction as they could not have foreseen a future amendment with retrospective effect. Therefore, the penalty levied is not sustainable.

The Tribunal held that the PCIT's order under Section 263 was not justified as the AO's assessment order was not erroneous or prejudicial to the revenue. The Tribunal also noted that initiation of penalty proceedings under Section 270A is discretionary and the conditions for levying penalty for under-reporting of income were not met.

The Tribunal held that the assessee banks cannot be treated as assessees in default under Section 201(1) of the Income Tax Act because they were legally bound to comply with the interim judicial directions. Consequently, the interest charged under Section 201(1A) was also set aside.

The Tribunal held that the assessee's denial of unaccounted transactions, coupled with M/s Tirth Gold's subsequent statement of only Rs. 20,038/- in purchases and lack of positive evidence from the AO, made the addition unsustainable. The Tribunal noted the difficulty in proving a negative and the lack of opportunity for cross-examination.

The Tribunal held that Section 153A/153C of the Income Tax Act has an overriding effect over Section 147 due to their non-obstante clauses. Therefore, the AO's action of reopening under Section 147 was without jurisdiction.

The Tribunal condoned the delay, set aside the CIT(A)'s ex-parte orders, and restored the matters to the file of the Assessing Officer for de novo assessment. Penalty orders were deleted, with liberty to initiate fresh proceedings if warranted.

The Tribunal held that the assessee banks cannot be treated as assessees in default under Section 201(1) of the Income Tax Act because they were legally bound to comply with the interim judicial directions. Consequently, the interest charged under Section 201(1A) was also set aside.

The Tribunal condoned the delay, set aside the CIT(A)'s ex-parte orders, and restored the matters to the file of the Assessing Officer for de novo assessment. Penalty orders were deleted, with liberty to initiate fresh proceedings if warranted.

The Tribunal condoned the delay, set aside the CIT(A)'s ex-parte orders, and restored the matters to the file of the Assessing Officer for de novo assessment. Penalty orders were deleted, with liberty to initiate fresh proceedings if warranted.

The Tribunal, considering CBDT Circular No. 9 of 2024 and Section 268A of the Income Tax Act, dismissed the Revenue's appeal due to the low tax effect (below Rs. 60 lakhs). The Department was granted liberty to seek a recall of the order if the tax effect is subsequently found to be higher or if the case falls within the circular's exceptions.

The Tribunal held that Section 153A/153C of the Income Tax Act has an overriding effect over Section 147 due to their non-obstante clauses. Therefore, the AO's action of reopening under Section 147 was without jurisdiction.

The Tribunal condoned the delay, set aside the CIT(A)'s ex-parte orders, and restored the matters to the file of the Assessing Officer for de novo assessment. Penalty orders were deleted, with liberty to initiate fresh proceedings if warranted.

The Tribunal condoned the delay, set aside the CIT(A)'s ex-parte orders, and restored the matters to the file of the Assessing Officer for de novo assessment. Penalty orders were deleted, with liberty to initiate fresh proceedings if warranted.

The Tribunal condoned the delay, set aside the CIT(A)'s ex-parte orders, and restored the matters to the file of the Assessing Officer for de novo assessment. Penalty orders were deleted, with liberty to initiate fresh proceedings if warranted.

The Tribunal held that Section 153A/153C of the Income Tax Act has an overriding effect over Section 147 due to their non-obstante clauses. Therefore, the AO's action of reopening under Section 147 was without jurisdiction.

The Tribunal condoned the delay, set aside the CIT(A)'s ex-parte orders, and restored the matters to the file of the Assessing Officer for de novo assessment. Penalty orders were deleted, with liberty to initiate fresh proceedings if warranted.

The Tribunal held that Section 153A/153C of the Income Tax Act has an overriding effect over Section 147 due to their non-obstante clauses. Therefore, the AO's action of reopening under Section 147 was without jurisdiction.

The Tribunal held that the assessee banks cannot be treated as assessees in default under Section 201(1) of the Income Tax Act because they were legally bound to comply with the interim judicial directions. Consequently, the interest charged under Section 201(1A) was also set aside.

The Tribunal held that the assessee banks cannot be treated as assessees in default under Section 201(1) of the Income Tax Act because they were legally bound to comply with the interim judicial directions. Consequently, the interest charged under Section 201(1A) was also set aside.

The Tribunal held that the assessee banks cannot be treated as assessees in default under Section 201(1) of the Income Tax Act because they were legally bound to comply with the interim judicial directions. Consequently, the interest charged under Section 201(1A) was also set aside.

The Tribunal held that the assessee banks cannot be treated as assessees in default under Section 201(1) of the Income Tax Act because they were legally bound to comply with the interim judicial directions. Consequently, the interest charged under Section 201(1A) was also set aside.

The Tribunal held that the assessee banks cannot be treated as assessees in default under Section 201(1) of the Income Tax Act because they were legally bound to comply with the interim judicial directions. Consequently, the interest charged under Section 201(1A) was also set aside.

The Tribunal held that the assessee banks cannot be treated as assessees in default under Section 201(1) of the Income Tax Act because they were legally bound to comply with the interim judicial directions. Consequently, the interest charged under Section 201(1A) was also set aside.

The Tribunal held that Section 153A/153C of the Income Tax Act has an overriding effect over Section 147 due to their non-obstante clauses. Therefore, the AO's action of reopening under Section 147 was without jurisdiction.

The Tribunal condoned the delay, set aside the CIT(A)'s ex-parte orders, and restored the matters to the file of the Assessing Officer for de novo assessment. Penalty orders were deleted, with liberty to initiate fresh proceedings if warranted.

The Tribunal noted that the subsequent grant of registration and approval rendered the appeal infructuous. As the assessee wished to withdraw the appeal, it was dismissed as withdrawn.

The Tribunal condoned the delay, set aside the CIT(A)'s order, and restored the matter to the AO. The assessee was directed to pay costs and given an opportunity to present their case with requisite evidence.

The Tribunal set aside the matter to the Jurisdictional AO with a direction to verify the additional evidence filed by the assessee regarding the TDS credit and allow it if the corresponding income was offered to tax.

The Tribunal set aside the matter to the Jurisdictional AO with a direction to verify the additional evidence filed by the assessee regarding the TDS credit and allow it if the corresponding income was offered to tax.

The Tribunal condoned the delay in filing the appeal and set aside the matter to the CIT(A) for fresh adjudication. The assessee was directed to make compliance before the CIT(A) and pay a cost of Rs. 10,000.

The Tribunal held that the notice issued under Section 148 for AY 2015-16 on April 8, 2021, was time-barred and without jurisdiction, following Supreme Court and High Court precedents. Consequently, the assessment order based on this invalid notice was quashed.

The Tribunal deleted the disallowance under Section 14A, relying on a Gujarat High Court decision. The other issues regarding sundry creditors and Section 80JJAA deduction were restored to the AO for fresh verification and speaking orders.

The Tribunal held that the assessee branches could not be treated as assessees in default under Section 201(1) of the Income Tax Act. This was because they were bound to comply with the interim judicial directions of the Madras High Court, which prevented them from deducting tax at source.

The Tribunal held that the assessee branches could not be treated as assessees in default under Section 201(1) of the Income Tax Act. This was because they were bound to comply with the interim judicial directions of the Madras High Court, which prevented them from deducting tax at source.

The Tribunal held that the assessee branches could not be treated as assessees in default under Section 201(1) of the Income Tax Act. This was because they were bound to comply with the interim judicial directions of the Madras High Court, which prevented them from deducting tax at source.

The Tribunal held that the assessee branches could not be treated as assessees in default under Section 201(1) of the Income Tax Act. This was because they were bound to comply with the interim judicial directions of the Madras High Court, which prevented them from deducting tax at source.

The Tribunal held that the assessee branches could not be treated as assessees in default under Section 201(1) of the Income Tax Act. This was because they were bound to comply with the interim judicial directions of the Madras High Court, which prevented them from deducting tax at source.

The Tribunal held that the assessee branches could not be treated as assessees in default under Section 201(1) of the Income Tax Act. This was because they were bound to comply with the interim judicial directions of the Madras High Court, which prevented them from deducting tax at source.

The Tribunal held that the assessee branches could not be treated as assessees in default under Section 201(1) of the Income Tax Act. This was because they were bound to comply with the interim judicial directions of the Madras High Court, which prevented them from deducting tax at source.

The Tribunal held that the assessee branches could not be treated as assessees in default under Section 201(1) of the Income Tax Act. This was because they were bound to comply with the interim judicial directions of the Madras High Court, which prevented them from deducting tax at source.