ITAT Bangalore Judgments — April 2026

The Tribunal held that the capital bond agreement clearly stipulated that interest accruing on the capital bond was to be paid by the assessee to Prestige. Therefore, the interest paid was an expenditure incurred by the assessee and eligible for deduction from the interest income earned on the capital bond.

The Tribunal held that the capital bond agreement clearly stipulated that interest accruing on the capital bond was to be paid by the assessee to Prestige. Therefore, the interest paid was an expenditure incurred by the assessee and eligible for deduction from the interest income earned on the capital bond.

The Tribunal held that additions made under Section 153C require incriminating material discovered during the search. Since the additions were based solely on bank statements and declared income, and the assessment years were concluded, the additions were not sustainable.

The Tribunal held that the capital bond agreement clearly stipulated that interest accruing on the capital bond was to be paid by the assessee to Prestige. Therefore, the interest paid was an expenditure incurred by the assessee and eligible for deduction from the interest income earned on the capital bond.

The tribunal considered the request for withdrawal of the appeal. As there was no objection from the revenue, the appeal was dismissed as withdrawn.

The Tribunal held that additions made under Section 153C require incriminating material discovered during the search. Since the additions were based solely on bank statements and declared income, and the assessment years were concluded, the additions were not sustainable.

The Tribunal held that additions made under Section 153C require incriminating material discovered during the search. Since the additions were based solely on bank statements and declared income, and the assessment years were concluded, the additions were not sustainable.

The Tribunal held that additions made under Section 153C require incriminating material discovered during the search. Since the additions were based solely on bank statements and declared income, and the assessment years were concluded, the additions were not sustainable.

The Tribunal held that additions made under Section 153C require incriminating material discovered during the search. Since the additions were based solely on bank statements and declared income, and the assessment years were concluded, the additions were not sustainable.

The Tribunal held that additions made under Section 153C require incriminating material discovered during the search. Since the additions were based solely on bank statements and declared income, and the assessment years were concluded, the additions were not sustainable.

The Tribunal found that the CIT(A) failed to decide the appeal on merits, merely dismissing it for non-compliance. The Tribunal restored the appeal to the CIT(A) for a fresh decision on merits, directing the assessee to cooperate.

The ITAT held that TDS is required on year-end provisions when the payee and amount are ascertainable, even if credited to an expenses payable account. However, the issue of tax liability on these provisions was restored to the AO to examine the benefit of the first proviso to Section 201. The tribunal also found that TDS on salary payments was correctly handled.

The Tribunal held that the assessee, being a co-operative society registered under the Karnataka Souharda Sahakari Act, 1997, is eligible for deduction under Section 80P(2)(a)(i) as per the Karnataka High Court's decision. Any disallowance for non-deduction of tax would also increase the deductible income.

The Tribunal held that the assessee, being a co-operative society registered under the Karnataka Souharda Sahakari Act, 1997, is eligible for deduction under Section 80P(2)(a)(i) as per the Karnataka High Court's decision. Any disallowance for non-deduction of tax would also increase the deductible income.

The Tribunal held that the assessee, being a co-operative society registered under the Karnataka Souharda Sahakari Act, 1997, is eligible for deduction under Section 80P(2)(a)(i) as per the Karnataka High Court's decision. Any disallowance for non-deduction of tax would also increase the deductible income.

The assessee's advocate filed a letter withdrawing all the pending appeals before the tribunal. Consequently, the tribunal dismissed all seven appeals as withdrawn.

The assessee's advocate filed a letter withdrawing all the pending appeals before the tribunal. Consequently, the tribunal dismissed all seven appeals as withdrawn.

The assessee's advocate filed a letter withdrawing all the pending appeals before the tribunal. Consequently, the tribunal dismissed all seven appeals as withdrawn.

The assessee's advocate filed a letter withdrawing all the pending appeals before the tribunal. Consequently, the tribunal dismissed all seven appeals as withdrawn.

The assessee's advocate filed a letter withdrawing all the pending appeals before the tribunal. Consequently, the tribunal dismissed all seven appeals as withdrawn.

The assessee's advocate filed a letter withdrawing all the pending appeals before the tribunal. Consequently, the tribunal dismissed all seven appeals as withdrawn.

The assessee's advocate filed a letter withdrawing all the pending appeals before the tribunal. Consequently, the tribunal dismissed all seven appeals as withdrawn.

The Tribunal held that the capital bond agreement clearly stipulated that interest accruing on the capital bond was to be paid by the assessee to Prestige. Therefore, the interest paid was an expenditure incurred by the assessee and eligible for deduction from the interest income earned on the capital bond.

The Tribunal held that the capital bond agreement clearly stipulated that interest accruing on the capital bond was to be paid by the assessee to Prestige. Therefore, the interest paid was an expenditure incurred by the assessee and eligible for deduction from the interest income earned on the capital bond.

The Tribunal held that the capital bond agreement clearly stipulated that interest accruing on the capital bond was to be paid by the assessee to Prestige. Therefore, the interest paid was an expenditure incurred by the assessee and eligible for deduction from the interest income earned on the capital bond.

The Tribunal held that the capital bond agreement clearly stipulated that interest accruing on the capital bond was to be paid by the assessee to Prestige. Therefore, the interest paid was an expenditure incurred by the assessee and eligible for deduction from the interest income earned on the capital bond.

The Tribunal held that the procedure prescribed under Section 144C of the Income Tax Act, 1961, is mandatory and not directory. Failure to follow this procedure constitutes a jurisdictional error, not merely a procedural one, and therefore, Section 292B cannot save an order passed in breach of Section 144C(1), as it is an incurable illegality. The Tribunal noted that Section 144C(1) is a non-obstante provision requiring compliance irrespective of other provisions. In this case, the AO computed the taxable income and tax payable, issued a notice of demand under section 156, and initiated penalty proceedings simultaneously with the draft assessment order. This action strikes at the root of the procedure contemplated by Section 144C. Following the jurisdictional High Court of Karnataka in CIT (International Taxation) v. Cisco Systems Services B.V. and the Bombay High Court in SHL (India) Private Limited Vs. Deputy Commissioner of Income Tax, the Tribunal concluded that the impugned final assessment order and consequential demand and penalty notice were bad in law. The Tribunal quashed the impugned final assessment order and consequential demand as well as the penalty notice. The cross-objection filed by the assessee was allowed, and the appeal filed by the revenue was dismissed.

The Tribunal held that the expenditure on infrastructure sharing charges was incurred wholly and exclusively for business purposes and directed its deletion. It also held that the credit balances represented genuine advances for exports and not a cessation of liability, thus allowing the appeal on this ground.

The Tribunal held that the expenditure on infrastructure sharing charges was incurred wholly and exclusively for business purposes and directed its deletion. It also held that the credit balances represented genuine advances for exports and not a cessation of liability, thus allowing the appeal on this ground.

The Tribunal partly allowed the appeal, directing the Assessing Officer (AO) to re-examine certain comparable companies and their margins. The AO was also instructed to verify if Hoya Medical India Private Limited breached the related party transaction filter and to examine the inclusion of Hicks Thermometer (India) Private Limited.

The Tribunal condoned the delay in filing the appeal, admitted additional evidence, and restored the appeal to the Assessing Officer for fresh examination. The Tribunal found sufficient cause for the delay and for not producing evidence earlier.

The Tribunal held that Board Circular No. 1916, which provides guidelines for non-seizure of jewelry, also applies to the taxation of unexplained investment in jewelry. Therefore, the addition to the extent of jewelry covered by the circular should be deleted.

The Tribunal held that the CIT(E) erred by not independently applying his mind to the facts and relying solely on the JAO's report. The Tribunal also noted that no personal hearing was granted. Therefore, the orders of the CIT(E) were set aside.

The Tribunal held that the CIT(E) erred by not independently applying his mind to the facts and relying solely on the JAO's report. The Tribunal also noted that no personal hearing was granted. Therefore, the orders of the CIT(E) were set aside.

The Tribunal acknowledged the assessee's reason for not submitting documents and decided to allow the appeal to provide an opportunity to present evidence. The issue was remitted back to the CIT(A) for fresh consideration.

The Tribunal held that the denial of FTC without proper reasoning or show cause notice was unfair. Relying on judicial precedents, the Tribunal directed the Assessing Officer to verify and grant the FTC, despite the delay in filing Form 67.

The Tribunal held that the penalty under Section 270A(9) for misreporting of income is vitiated if the specific limb of default is not mentioned in the assessment order or show cause notice. The assessee was not aware of the specific charge of misrepresentation or suppression of facts until the penalty order.

The Tribunal held that since the assessee failed to file a petition for condonation of delay with sufficient cause, the appeal could not be admitted. Consequently, the appeal was dismissed without condoning the delay.

The Tribunal condoned the delay, finding sufficient cause due to the communication lapse beyond the assessee's control. The appeal was restored to the CIT(A) for a fresh hearing on merits.

The Tribunal held that the assessee had a reasonable cause and a bonafide belief that accepting cash loans of exactly Rs. 20,000 each did not violate Section 269SS. Therefore, the penalty levied under Section 271D was directed to be deleted.

The Tribunal noted that the application was indeed for Section 80G approval and the CIT had erred in treating it as a Section 12AB registration. The assessee's inability to represent its case due to the CA's workload was also considered.

The Tribunal, considering the assessee's request for another opportunity and the foundation's role in tiger conservation, decided to remit the issue back to the CIT(Exemptions) for a fresh decision. The assessee was directed to produce all relevant documents.

The Tribunal held that the notice initiating penalty proceedings under Section 274 read with Section 271(1)(c) was invalid as it was unsigned. Consequently, the subsequent penalty order was also quashed.

The Tribunal held that the approval for the reassessment proceedings was obtained from an incorrect authority, violating Section 151(ii) of the Act. Consequently, the reassessment order and the notice under Section 148 were quashed.

The Tribunal held that the delay in filing Form 56F would not be fatal to the substantial claim for deduction under Section 10AA. Following the decision of the Hon'ble Madras High Court, the Tribunal directed the Assessing Officer to grant the deduction.

The Tribunal considered the application for withdrawal dated 9.4.2026 filed by the assessee and the request of the assessee's authorized representative. The Tribunal permitted the assessee to withdraw the appeal. Consequently, the appeal filed by the assessee was dismissed as withdrawn. The operative direction was to dismiss the appeal. No specific issues were decided on merits as the appeal was withdrawn. The judgment does not record any specific finding on the merits of the AO's order or the applicability of the APA beyond permitting the withdrawal.

The Tribunal permitted the assessee to withdraw the appeal as no objection was raised by the Revenue. Consequently, the appeal was dismissed as withdrawn.

The Tribunal held that the reassessment proceedings were time-barred as the conditions for invoking the extended period under Section 149(1)(b) were not met. The AO did not possess evidence to suggest income escaping assessment of Rs. 50 lakhs or more.

The Tribunal found that the assessee had a reasonable cause for not responding to the notices, considering his lack of awareness of tax proceedings and his profession. Therefore, the penalty levied under Section 271(1)(b) was deleted by virtue of Section 273B.

The Tribunal held that determining the ALP at 'Nil' for management fees, SAP implementation costs, and technology license fees was incorrect. It followed its own prior decisions and directed the deletion of these adjustments, allowing the appeal on these grounds.