ITAT Amritsar Judgments — August 2026

The Tribunal allowed the claim for prior period expenses, relying on judicial precedents that allow deduction when liability is ascertained. For TDS disallowances on reimbursements, the matter was remanded for fresh verification.

The Tribunal deleted the addition related to printing charges paid to a sister concern, finding it to be a genuine business need. The addition concerning unsold and complimentary copies was also deleted as the assessee provided a satisfactory breakup and explanation.

The Tribunal held that payments to press reporters and photographers for intellectual services are not covered under Section 194C or 194J. Reimbursement of railway freights paid to CONCOR was also held to be outside the purview of Section 194C. The Tribunal deleted the addition on account of FBT as the items were distributed to outsiders for a readers' survey and not to employees.

The Tribunal allowed the claim for prior period expenses, relying on judicial precedents that allow deduction when liability is ascertained. For TDS disallowances on reimbursements, the matter was remanded for fresh verification.

The Tribunal held that the first appellate authority should have provided an opportunity of hearing to the assessee on principles of natural justice to explain the delay and the non-payment of admitted tax. Therefore, the matter was remanded back to the first appellate authority.

The Tribunal held that the replacement of burnt wires was a revenue expenditure as it was necessary to bring an existing asset back to its original working condition and did not create a new asset or increase its capacity or value.

The Tribunal held that the replacement of burnt wires was a revenue expenditure as it was necessary to bring an existing asset back to its original working condition and did not create a new asset or increase its capacity or value.

The Tribunal held that the replacement of burnt wires was a revenue expenditure as it was necessary to bring an existing asset back to its original working condition and did not create a new asset or increase its capacity or value.

The Tribunal deleted the addition related to printing charges paid to a sister concern, finding it to be a genuine business need. The addition concerning unsold and complimentary copies was also deleted as the assessee provided a satisfactory breakup and explanation.

The Tribunal deleted the addition related to printing charges paid to a sister concern, finding it to be a genuine business need. The addition concerning unsold and complimentary copies was also deleted as the assessee provided a satisfactory breakup and explanation.

The Tribunal held that the rejection of book results was not justified as no specific defects were pointed out. The addition on account of stock was partly allowed, reducing the addition. Additions under Section 40A(3) and for prior period expenses were deleted.

The Tribunal held that payments to press reporters and photographers for intellectual services are not covered under Section 194C or 194J. Reimbursement of railway freights paid to CONCOR was also held to be outside the purview of Section 194C. The Tribunal deleted the addition on account of FBT as the items were distributed to outsiders for a readers' survey and not to employees.

The Tribunal remanded the issue of disallowance under Section 40(a)(ia) back to the AO for fresh verification. The disallowance for prior period expenses was deleted, and the disallowance for sales promotion expenses was allowed. The addition under Section 41(1) was remanded to the AO for further consideration.

The Tribunal held that the disallowance under Section 40(a)(ia) for payments to press reporters and photographers requires fresh verification by the AO, considering the nature of services and agreements. The additions for repairs and maintenance were held to be revenue in nature and thus allowable.

The Tribunal allowed the repair expenses as revenue expenditure, following Supreme Court and High Court precedents. However, it held that for tax purposes, different units operating under the same PAN are treated as a single taxable entity, thus disallowing the set-off of losses from one unit against another.

The Tribunal allowed the claim for prior period expenses, relying on judicial precedents that allow deduction when liability is ascertained. For TDS disallowances on reimbursements, the matter was remanded for fresh verification.

The Tribunal held that since the repairs were made to maintain the leased premises in a usable condition as per the lease agreement and did not result in the acquisition of a capital asset or enduring benefit, they should be treated as revenue expenditure. The Tribunal relied on Supreme Court and jurisdictional High Court judgments.

The Tribunal held that since both units operate under the same PAN, they are treated as a single taxable entity. Therefore, losses and profits must be computed collectively for taxation purposes.

The Tribunal held that the matter should be remanded to the AO for fresh adjudication. The AO needs to consider the submissions and evidence provided by the assessee to correct any errors.

The Tribunal agreed with the CIT(A) that the mistake was apparent from the record and the AO was justified in rectifying the order under Section 154 to recompute tax as per Section 115BBE, given the additions were made under deeming provisions.

The Tribunal held that the matter should be remanded to the AO for fresh adjudication. The AO needs to consider the submissions and evidence provided by the assessee to correct any errors.

The Tribunal allowed the deduction under Section 80P(2)(d). It followed the jurisdictional High Court's decision in CIT vs. Doaba Cooperative Sugar Mills Ltd., which held that the source of investment is not relevant for claiming deduction as long as it's with another cooperative society.

The Tribunal held that the addition based on Annexure A-22, which pertained to the assessee's husband's business entities, was unsustainable. It also found that the presumption under Section 292C was rebutted by evidence indicating the entities belonged to the husband.

The Tribunal held that the addition based on Annexure A-22, which pertained to the assessee's husband's business entities, was unsustainable. It also found that the presumption under Section 292C was rebutted by evidence indicating the entities belonged to the husband. The disallowance for non-deduction of TDS was also questioned when books were rejected.

The Tribunal held that the transactions were recorded in the firm's books and the partners' capital contributions were sourced from their explained income as government contractors. Therefore, the addition made under Section 69A was deleted.

The Tribunal found that while some deposits were explained by prior withdrawals, a portion of Rs. 13.10 lakhs remained unexplained. Therefore, the addition was restricted to this amount.

The Tribunal held that the matter should be remanded to the AO for fresh adjudication. The AO needs to consider the submissions and evidence provided by the assessee to correct any errors.

The Tribunal accepted that the cash deposit was from the sale of medicines and directed the AO to estimate the gross turnover from the medicine business at Rs. 75 lakhs, applying a net profit of 4%. The addition under Section 69A was deleted as it was considered part of the business turnover.

The Tribunal held that the CIT(A) failed to consider the assessee's written submissions and denied an opportunity for video hearing, violating principles of natural justice. The matter was remanded for fresh adjudication.

The Tribunal held that the addition based on Annexure A-22, which pertained to the assessee's husband's business entities, was unsustainable. It also found that the presumption under Section 292C was rebutted by evidence indicating the entities belonged to the husband. The disallowance for non-deduction of TDS was also questioned when books were rejected.

The Tribunal held that the rejection of the application for approval under Section 80G(5) by the CIT(E) was not justified. The Tribunal found that the assessee holds a valid 12AB registration as 'Charitable' and its audited financials show NIL expenditure on religious activities. The society is wholly engaged in educational activities, which are charitable under Section 2(15). The expenditures are related to running educational institutions. The dominant objects of the MOA are social welfare and educational development. The presence of a religious clause in the MOA was considered a 'dormant clause' with no actual spending. The Tribunal noted that Section 80G(5B) permits up to 5% expenditure on religious purposes without losing eligibility, and in this case, the expenditure was NIL. Therefore, there was no cause for apprehension of misuse. The Tribunal concluded that there was a non-application of mind by the CIT(E) to the facts on record and directed the CIT(E) to grant the approval under Section 80G(5). The appeal in ITA 898/ASR/2025 was allowed. The second appeal, ITA 952/ASR/2025, was dismissed as infructuous because it dealt with the same issue and was filed after the first appeal was decided in favor of the assessee.

The Tribunal held that the CIT(E) erred in rejecting the application based solely on the website and bank account details, overlooking substantial documentary evidence of charitable activities. The Tribunal directed the CIT(E) to grant registration, stating that exemption claims can be examined during assessment.

The Tribunal held that the rejection of the application for approval under Section 80G(5) by the CIT(E) was not justified. The Tribunal found that the assessee holds a valid 12AB registration as 'Charitable' and its audited financials show NIL expenditure on religious activities. The society is wholly engaged in educational activities, which are charitable under Section 2(15). The expenditures are related to running educational institutions. The dominant objects of the MOA are social welfare and educational development. The presence of a religious clause in the MOA was considered a 'dormant clause' with no actual spending. The Tribunal noted that Section 80G(5B) permits up to 5% expenditure on religious purposes without losing eligibility, and in this case, the expenditure was NIL. Therefore, there was no cause for apprehension of misuse. The Tribunal concluded that there was a non-application of mind by the CIT(E) to the facts on record and directed the CIT(E) to grant the approval under Section 80G(5). The appeal in ITA 898/ASR/2025 was allowed. The second appeal, ITA 952/ASR/2025, was dismissed as infructuous because it dealt with the same issue and was filed after the first appeal was decided in favor of the assessee.

The Tribunal held that the Commissioner of Income Tax (Exemption) arrived at an incorrect conclusion without appreciating the audited financials, which clearly indicated no expenditure on religious activities. The reliance on the decision in Upper Ganges Sugar Mills Ltd v CIT was deemed unjustified as the assessee's objects were wholly and substantially charitable, not religious. The Tribunal observed that the religious activity clause in the trust deed was a 'dormant clause' with no actual expenditure incurred. In the absence of any such expenditure, rejection of approval under Section 80G(5) was not justified. The Tribunal also referred to the Rajasthan High Court decision in Umaid Charitable Trust v UOL, emphasizing that the dominant object of the trust and the actual expenditure are crucial. Furthermore, Section 80G(5B) permits expenditure up to 5% of total income for religious purposes. Considering the financials showing NIL expenses for religious activity and the lack of a show cause notice, the Tribunal set aside the matter to the CIT(E) for fresh reconsideration of the application after providing a proper opportunity of being heard. The appeal was allowed for statistical purposes.

The Tribunal held that the CIT erred in classifying the trust as religious when its activities and objects were predominantly charitable. The Tribunal directed the CIT to grant registration as a charitable trust.

The Tribunal held that the CIT erred in classifying the trust as religious when its activities and objects were predominantly charitable. The Tribunal directed the CIT to grant registration as a charitable trust.

The Tribunal held that the CIT erred in rejecting the registration application solely on the ground of no activities in the preceding three years. The focus at the registration stage should be on the objects of the trust and a prima facie satisfaction of genuineness, not the quantum of past activities.

The Tribunal held that the CIT erred in cancelling the assessee's application without affording a proper opportunity of being heard. The matter was remanded back to the CIT for fresh consideration.

The Tribunal held that the CIT erred in rejecting the application without issuing a show cause notice and affording an adequate opportunity of being heard. The Tribunal also found that limited activities or a single donation do not automatically disqualify a trust from registration.

The Tribunal held that the CIT erred in rejecting the application without affording the assessee a proper opportunity to present its case. The rejection was therefore set aside.

The Tribunal held that at the registration stage, the genuineness of the trust's objects and proposed activities should be examined, not just past activities. The CIT's rejection based solely on the absence of current activities was incorrect.

The Tribunal held that at the registration stage, the genuineness of the objects and proposed activities are to be examined, not necessarily completed activities. The CIT's rejection was based on an incorrect conclusion.

The Tribunal held that the order rejecting the application for registration under Section 12A(1)(ac)(ii) was bad in law as it was passed without providing the appellant with a proper opportunity to be heard. The cancellation of registration under Section 12AB was also deemed unjustified without prior notice.

The Tribunal condoned the delay in filing the appeal. It held that the interest of justice would be served by remanding the matter back to the CIT(A) for fresh adjudication, allowing the assessee an opportunity to present evidence and plead his case.

The Tribunal allowed the repair expenses as revenue expenditure, following Supreme Court and High Court precedents. However, it held that for tax purposes, different units operating under the same PAN are treated as a single taxable entity, thus disallowing the set-off of losses from one unit against another.

The Tribunal condoned the delay of 137 days, finding that the assessee may not have received the assessment order. The matter was remanded to the CIT(A) for adjudication on merits, with a direction to provide the assessee an opportunity of being heard.

The Tribunal held that the rejection of the application was based on an inspector's report without providing the assessee an opportunity to rebut the findings, thus violating principles of natural justice. The matter was remanded for fresh consideration.

The Tribunal found that running a school is a charitable activity. It remanded the matter back to the CIT (Exemptions) for fresh consideration, directing the assessee to provide all documentary evidence and cooperate with the proceedings.