ITAT Amritsar Judgments — April 2026

The Tribunal noted that the issue challenging the reassessment proceedings under Section 147 had not been adjudicated by the first appellate authority as it was not raised in the grounds of appeal before him. Given the contradictory claims by both parties regarding the completeness of the disclosure and the materials on record, and in the interest of justice, the Tribunal decided to remand the matter back to the Ld. first appellate authority. The first appellate authority is directed to adjudicate on this additional ground after consulting the assessment records or obtaining a report from the AO. The assessee is directed to fully cooperate in the appellate proceedings by filing all necessary submissions. The assessee will be allowed a reasonable opportunity of being heard, including video hearing. The additional ground taken by the assessee is allowed for statistical purposes. The appeal of the assessee is partly allowed for statistical purposes.

The Tribunal held that the PCIT did not provide a reasonable opportunity to the assessee to present their case in the revision proceedings. The limited time provided and the procedural irregularities violated the principles of natural justice.

The Tribunal held that the PCIT did not provide a reasonable opportunity to the assessee to present their case in the revision proceedings. The limited time provided and the procedural irregularities violated the principles of natural justice.

The Tribunal held that the PCIT did not provide a reasonable opportunity to the assessee to present their case in the revision proceedings. The limited time provided and the procedural irregularities violated the principles of natural justice.

The Tribunal condoned the delay in filing the appeal before it, citing the medical emergency of the assessee's counsel and lack of proper service of the CIT(A)'s order. The Tribunal set aside the matter to the AO for fresh assessment 'denovo' after considering the documentary evidence filed by the assessee.

The Tribunal held that Section 12AB(4), which deals with cancellation of registration for specified violations, is not applicable retrospectively. The alleged violations occurred before the introduction of this section, and therefore, the cancellation was not legally justified.

The Tribunal noted that the assessee failed to present evidence before the CIT(Appeals) due to inadvertence, leading to an ex-parte decision. Considering the interest of substantive justice and the need for proper adjudication, the matter was remanded.

The Tribunal noted that the assessee failed to present evidence before the CIT(Appeals) due to inadvertence, leading to an ex-parte decision. Considering the interest of substantive justice and the need for proper adjudication, the matter was remanded.

The Tribunal noted that the quantum appeal related to the same assessment year had been remanded back to the CIT(A). Therefore, in the interest of justice, the Tribunal set aside the impugned order and remanded the matter back to the CIT(A) for fresh adjudication.

The Tribunal found that the CIT(A) had deleted the addition on cash deposits without critically analyzing the facts and evidence. Therefore, this specific ground was remanded to the AO for fresh adjudication. All other grounds of appeal were dismissed.

The Tribunal held that the reassessment proceedings were invalid and void ab initio because the AO initiated them based on incorrect facts and without proper application of mind. The alleged transactions did not belong to the assessee company.

The Tribunal noted that the quantum additions forming the basis for the penalty were quashed. While the Revenue mentioned a pending High Court appeal against the quantum deletion, they failed to provide proof. The Tribunal held that deciding on penalty while the quantum is disputed is premature.

The tribunal held that the ex parte order passed by the CIT(A) was without issuing notice to the correct e-mail id, violating the principles of natural justice. Therefore, the matter was remanded back to the first appellate authority.

The Tribunal found that the assessee had not presented arguments on merits at any stage and had raised new grounds regarding the limitation of the notice under section 148. Since the assessment order lacked a date-wise sequence of events for proper calculation and this issue was not adjudicated by the lower authorities, the matter was remanded.