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The Tribunal noted that the AO's addition under Section 68 might lead to double taxation if the amounts were already offered as income. The Tribunal found that while the assessee failed to provide adequate details, the issue of verification of cash deposits and their taxability needed further examination.
The Tribunal condoned the delay in filing the appeal, stating that the assessee's unawareness of the assessment order until penalty proceedings and subsequent engagement of a Chartered Accountant constituted sufficient cause. It further held that the Assessing Officer's addition of the entire sale consideration without allowing for cost of acquisition or construction was unjust. The case was remanded back to the Assessing Officer to allow the assessee 90 days to substantiate her claims regarding construction and acquisition costs and other expenses.
The Tribunal held that the Assessing Officer incorrectly invoked Section 69A by isolating only the demonetization period deposits without considering the overall pattern of bank transactions. The consistent cash flow indicated small-scale business activities, and the omission of business income appeared to be a mistake.
The Tribunal held that interest earned from temporary parking of surplus funds in banks by a cooperative society engaged in providing credit facilities is attributable to its business and eligible for deduction under Section 80P(2)(a)(i). However, the AO needs to verify the source of funds for these investments.
The Tribunal held that the Assessing Officer is duty-bound to dispose of objections raised by the assessee against the reopening proceedings by passing a speaking order before passing the reassessment order. Failure to do so vitiates the assessment order. Following the decisions of the Hon'ble Supreme Court and Karnataka High Court, the Tribunal quashed the reassessment.
The Tribunal held that the notice u/s 148 was validly issued on March 31, 2021, based on ITBA portal records, and the amended provisions of the Finance Act, 2021, were not applicable. The Tribunal also found the AO's estimation of gross receipts and profit rate to be unsubstantiated and modified the profit rate.
The Tribunal condoned the delay of 741 days in filing the appeal due to the assessee's serious medical condition. It held that the assessee could not properly present his case before the lower authorities due to his medical issues and the assessment/appellate proceedings were completed without effective participation.
The Tribunal held that the assessee made bona fide efforts to comply and appeared before the authority. The rejection appeared to be without adequate consideration of submitted documents, and the matter required fresh examination by the CIT(E).
The Tribunal deleted the addition under Section 68 as the assessee had provided a ledger showing the opening balance was accepted. The issue of expenses treated as capital was remanded for further verification. The addition based on Form 26AS was also remanded to the AO to verify if the income was offered in the subsequent year, to avoid double taxation.
The Income Tax Appellate Tribunal (ITAT) noted that the appeal against the Section 143(1) intimation, which contained the disputed addition, was subsequently allowed by the CIT(A) on 13.12.2025, finding the addition incorrect. Consequently, the ITAT held that the assessed income should be the same as the assessee's returned income and allowed the appeal, directing the Assessing Officer to recompute the total income.
The Tribunal held that the assessee had satisfactorily explained the source of cash deposits, as the total deposits were within the available cash balance as per the books. The AO's ad hoc restriction of the cash balance to ₹7 Lakhs lacked legal or factual foundation. The Tribunal also relied on judicial precedent stating that if an investment outside books is not proved, the assessee cannot be asked to prove its source.
The Tribunal held that a separate satisfaction note is required for each Assessment Year under Section 153C of the IT Act, and a consolidated note vitiates the assessment proceedings. Relying on the judgment of the Hon'ble Jurisdictional High Court, which was affirmed by the Supreme Court, the Tribunal found the notice issued u/s. 153C to be invalid.
The Tribunal held that a separate satisfaction note is required for each Assessment Year under Section 153C of the IT Act, and a consolidated note vitiates the assessment proceedings. Relying on the judgment of the Hon'ble Jurisdictional High Court, which was affirmed by the Supreme Court, the Tribunal found the notice issued u/s. 153C to be invalid.
The Tribunal held that a separate satisfaction note is required for each Assessment Year under Section 153C of the IT Act, and a consolidated note vitiates the assessment proceedings. Relying on the judgment of the Hon'ble Jurisdictional High Court, which was affirmed by the Supreme Court, the Tribunal found the notice issued u/s. 153C to be invalid.
The Tribunal held that a separate satisfaction note is required for each Assessment Year under Section 153C of the IT Act, and a consolidated note vitiates the assessment proceedings. Relying on the judgment of the Hon'ble Jurisdictional High Court, which was affirmed by the Supreme Court, the Tribunal found the notice issued u/s. 153C to be invalid.
The Tribunal held that on the date of intimation, the jurisdictional High Court (Karnataka) had ruled in favour of the assessee, stating that employee contributions deposited before the due date of filing the return are allowable. Therefore, the adjustment made by CPC under section 143(1)(a)(iv) was incorrect.
The Tribunal held that a separate satisfaction note is required for each Assessment Year under Section 153C of the IT Act, and a consolidated note vitiates the assessment proceedings. Relying on the judgment of the Hon'ble Jurisdictional High Court, which was affirmed by the Supreme Court, the Tribunal found the notice issued u/s. 153C to be invalid.
The Tribunal observed that the reasons provided for the delay were general workload claims common to all assessing officers and did not constitute sufficient cause. The registry's calculation of the delay also contradicted the grounds presented by the Assessing Officer.
The Tribunal held that a separate satisfaction note is required for each Assessment Year under Section 153C of the IT Act, and a consolidated note vitiates the assessment proceedings. Relying on the judgment of the Hon'ble Jurisdictional High Court, which was affirmed by the Supreme Court, the Tribunal found the notice issued u/s. 153C to be invalid.
The Tribunal held that on the date of intimation, the jurisdictional High Court (Karnataka) had ruled in favour of the assessee, stating that employee contributions deposited before the due date of filing the return are allowable. Therefore, the adjustment made by CPC under section 143(1)(a)(iv) was incorrect.
The assessee withdrew the appeal, citing that they have challenged the impugned orders before the Hon'ble Karnataka High Court. The Ld. DR had no objection to the withdrawal.
The Tribunal held that the addition made under section 143(1) based solely on an inadvertent error in the original tax audit report was unsustainable. The assessee's subsequent clarifications and revised reports, supported by financial statements, demonstrated no actual provision for gratuity was created. The Tribunal also directed the AO to verify and grant short-claimed TDS credit.
The Tribunal held that while the assessee's explanation had inconsistencies, the AO failed to conduct necessary verification. Suspicion alone cannot replace proof, and the addition was not sustainable without proper investigation.
The Tribunal held that a notice issued under section 143(2) to a deceased assessee is a jurisdictional notice and renders the entire assessment proceedings null and void. Consequently, the subsequent assessment order is non-est.
The Tribunal noted the consistent pattern of negligence and lack of diligence by the assessee in responding to statutory notices and filing appeals, leading to ex-parte assessments and significant delays. While acknowledging these lapses, the Tribunal, in the interest of substantial justice, decided to grant one more opportunity to examine the issue on merits.
The Tribunal noted the assessee's consistent pattern of negligence and delay in proceedings, including before the CIT(A) and the Tribunal itself. However, to provide an opportunity for examining the matter on merits after an ex parte assessment, the Tribunal condoned the delay in filing, imposed a cost, and restored the issue to the Assessing Officer for fresh adjudication.
The Tribunal noted that the assessee had revised his computation treating cash deposits as turnover under Section 44AD. The AO rejected this and treated the entire deposit as unexplained income. The Tribunal found that the AO's findings were not clear regarding the revised computation and the disallowance of expenditure was made on an ad-hoc basis without specific defects being pointed out.
The Tribunal condoned the delay in filing the appeal in the interest of justice, recognizing the assessee's challenges in communication and accounting. An opportunity was granted to the assessee to produce records to substantiate their claim regarding profit margins.
The Tribunal held that the transaction concerning the immovable property did not constitute a transfer in the relevant year, as it was superseded by a partition decree. The disallowance of agricultural income was set aside due to lack of cogent reasons and the principle of consistency. The addition for A.Y. 2014-15, based solely on a statement without corroborative evidence, was also deleted.
The Tribunal upheld the PCIT's order, finding that the AO had failed to conduct necessary inquiries regarding the provision, quantification, and use of refund liabilities. This lack of inquiry rendered the assessment order erroneous and prejudicial to the interests of revenue.
The Tribunal held that excess expenditure incurred in earlier assessment years can be set off against the income of the current year by invoking Section 11 of the Act. The issue was remitted to the AO for verification and allowing the set off.
The Tribunal held that the transaction concerning the immovable property did not constitute a transfer in the relevant year, as it was superseded by a partition decree. The disallowance of agricultural income was set aside due to lack of cogent reasons and the principle of consistency. The addition for A.Y. 2014-15, based solely on a statement without corroborative evidence, was also deleted.
The Tribunal held that the approval granted by the PCIT(Central) under Section 151 of the Act was not sustainable in law as it was based on a factually erroneous premise that the assessee was a non-filer. Consequently, the reassessment proceedings were vitiated.
The Tribunal held that the assessee had provided sufficient documentary evidence, including the JDA and bank statements, to explain the source of the capital. The Tribunal noted that the withdrawals followed the deposits and that the revenue had not produced contrary material. It was also held that if the source of funds introduced by a partner is not satisfactorily explained, the issue should be examined in the hands of the partner, not the firm.
The Tribunal held that the assessee had satisfactorily explained the nature and source of the cash deposits of ₹4,96,000/-. The addition sustained by the CIT(A) was not sustainable as the withdrawals were evidenced by bank records and reflected in the books of account.
The Tribunal condoned the delay in filing the appeal, citing sufficient cause. On merits, the Tribunal held that the addition of Rs. 3,50,000/- was not sustainable as the assessee had explained the agricultural income and it was exempt under Section 10(1). The Tribunal also noted that the reassessment was initiated for a different reason (investment in land) and no addition was made on that ground.
The Tribunal held that the cash deposits were business receipts from wholesale trading and not unexplained money. The addition was restricted to the gross profit already offered by the assessee, as the entire amount could not be taxed twice.
The Tribunal held that the notice issued under section 148 of the Act and the consequent reassessment proceedings were barred by limitation. The reassessment order was set aside and quashed as invalid.
The Tribunal held that the assessee had provided sufficient documentary evidence to prove the genuineness of its purchases. The AO failed to establish with cogent material that the purchases were merely accommodation entries, and the CIT(A)'s estimation of income was based on surmises.
The Tribunal held that the CIT(A) erred in admitting additional evidence without following the procedures laid down in Rule 46A of the Income Tax Rules. The CIT(A) should have obtained a remand report from the AO before admitting the documents and allowing the appeal.
The Tribunal held that the Commissioner (Appeals), when exercising the power to set aside an assessment under Section 251(1)(a) in a best judgment assessment, must either adjudicate all issues on merits or set aside the entire assessment for fresh consideration. A partial remand of one issue while sustaining others amounts to an improper exercise of appellate jurisdiction.
The Tribunal noted that the cash deposits were reflected in the bank account and explained as business receipts, recorded in the books of account. The essential conditions for invoking Section 69A, particularly that the money is not recorded in books and the explanation is unsatisfactory, were not met.
The Tribunal acknowledged the delay in filing the appeal and condoned it due to circumstances beyond the assessee's control. The Tribunal found that both the assessment and appellate orders were passed ex-parte without proper examination of evidence.
The Tribunal allowed Ground No. 11, directing the Assessing Officer (AO) to verify the reconstructed financial data of 'R Systems International Ltd.' and, if satisfied, include it as a comparable. This decision is based on the principle that if a public listed entity's data can be reconstructed and it meets FAR criteria, it should not be excluded solely on the basis of a different financial year, especially when it passes other filters. The Tribunal also allowed Ground No. 15, remanding the issue of working capital adjustment and the treatment of overdue receivables back to the AO. The AO is directed to re-examine if these transactions are closely linked and if working capital adjustment subsumes them, and to benchmark them together if satisfied. The Tribunal admitted the additional ground regarding foreign tax credit, directing the AO to verify the claim of Rs.63,29,484 and to decide on the eligibility of deduction for foreign tax paid under Section 37(1) of the Act. The AO is also to consider the enhancement of foreign tax credit if the assessed income is enhanced. The Tribunal noted that some grounds were not contested and dismissed them, while others were not argued and were also dismissed.
The Tribunal held that assessees registered under the Karnataka Souharda Sahakari Act, 1997, are to be treated as cooperative societies eligible for deduction u/s 80P. The disallowance u/s 40(a)(ia) for TDS on interest payments to members was incorrect due to exemption under section 194A(3)(v). The disallowance of provision for NPA was also not correct, as it would have tax-neutral effect and is eligible for deduction u/s 80P.
The Tribunal found that while the reasons for the delay were not sufficiently explained, the assessee had provided chronological events and appeared to be under the impression that a detailed submission could be made during the personal hearing, which was not granted. Therefore, the Tribunal set aside the CIT(A)'s orders.
The Tribunal found that while the reasons for the delay were not sufficiently explained, the assessee had provided chronological events and appeared to be under the impression that a detailed submission could be made during the personal hearing, which was not granted. Therefore, the Tribunal set aside the CIT(A)'s orders.
The Tribunal held that the business receipts were supported by VAT returns and sales registers, and the deposits from relatives were substantiated by affidavits. Therefore, the additions were not justified.
The Tribunal held that the presence of nominal members does not disentitle the society from claiming deduction under Section 80P(2)(a)(i). It also ruled that interest income earned from cooperative banks, which are a type of cooperative society, is eligible for deduction under Section 80P(2)(d).
The Tribunal held that the four-year delay in filing the appeal should be condoned as it was due to a genuine mistake in mentioning the assessment year and the assessee had acted diligently to correct it. Further, following the Karnataka High Court's decision, the assessee, being registered under the Karnataka Souharda Sahakari Act, is eligible for deduction under section 80P.