ITAT Amritsar Judgments — April 2026

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.

The Tribunal upheld the CIT(A)'s decision to delete additions related to unsecured loans, undisclosed sales, and sundry creditors, finding the assessee's explanations acceptable. However, the Tribunal disagreed with the CIT(A) regarding the deletion of additions for unexplained cash deposits. The Tribunal observed a shortfall in explained cash availability compared to cash deposited in banks, indicating incomplete verification by the lower authorities.

The Tribunal held that the reassessment proceedings were invalid and void ab initio. The addition was made based on incorrect assumptions of fact and a lack of application of mind by the AO. The evidence, including MCA records and bank statements, confirmed that the alleged transactions did not relate to the assessee but to a different entity.