ITAT Amritsar Judgments — August 2025

The Tribunal dismissed the legal challenge to the reassessment proceedings. However, it deleted the additions made under Section 2(22)(e) and for unexplained old investments, finding the former to be normal running account transactions and the latter not supported by current year's cash flow. The proportionate estimated addition of agricultural income was upheld.

The ITAT upheld the CIT(A)'s decision, confirming that the revaluation of inherited properties in the balance sheet for disclosure purposes, without an actual sale or transfer, does not attract capital gains tax. The Tribunal concluded that since there was no transfer of capital assets, Sections 45 and 49 of the Income Tax Act were not applicable, and the addition made by the AO was not sustainable.

Considering the principles of natural justice and potential communication gaps in the faceless assessment regime, the Tribunal set aside the impugned order. It directed the Assessing Officer to conduct a fresh assessment, with the assessee being instructed to present and prove their case without delay.

The Tribunal, invoking principles of natural justice and acknowledging potential communication gaps in the faceless regime, set aside the CIT(A)'s order. The case was restored to the CIT(A) for a de novo adjudication, granting the assessee a fresh opportunity to present their case.

Recognizing natural justice principles and potential communication gaps in the faceless regime, the Tribunal condoned the delay and admitted the appeal. The CIT(A) order was set aside, and the matter was restored to the CIT(A) for a de novo adjudication, granting the assessee another opportunity to present its case.

The Tribunal condoned the 78-day delay by the assessee. It restored both the quantum appeal and the consequential penalty appeals back to the file of the CIT(A) for fresh adjudication on merits, with a direction for the assessee to present and prove its case.

The Tribunal affirmed the deletion of penalties, holding that once the quantum additions, which formed the basis for the penalties under section 271(1)(c), had been deleted by the Tribunal and confirmed by the High Court, the consequential penalties could not legally survive. Therefore, both appeals filed by the revenue were dismissed.