ITAT Bangalore Judgments — May 2026

The Tribunal condoned the delay in filing the appeals, citing sufficient cause shown by the assessee and emphasizing the principle of substantial justice over technicalities. The matters were then remitted back to the lower appellate authority for fresh adjudication on merits.

The Tribunal held that booking a flat and making substantial payments within the statutory period, even if the sale deed is registered later, qualifies for deduction under Section 54F. The intention of the beneficial provision is to encourage housing investment.

The Tribunal upheld the CIT(A)'s decision, allowing the deduction for ESOP expenses based on the jurisdictional High Court's ruling and dismissing the disallowance under Section 14A as no exempt income was earned. Both appeals filed by the Revenue were dismissed.

The Tribunal held that the interest income earned by the assessee from banks, where members' money was deposited, is attributable to the business of borrowing and lending with members. The Tribunal also found that the disallowance of provision for expenses was unjustified.

The Tribunal condoned the delay in filing the appeal before the CIT(A), finding sufficient cause due to the assessee's non-resident status and reliance on an accountant. The quantum appeal was remanded to the CIT(A) for adjudication on merits.

The Tribunal condoned the delay in filing the appeals, citing sufficient cause shown by the assessee and emphasizing the principle of substantial justice over technicalities. The matters were then remitted back to the lower appellate authority for fresh adjudication on merits.

The Tribunal held that the compensation received under the BSNL VRS Scheme, 2019, qualifies for full exemption under Section 10(10B) of the Income Tax Act, 1961. It also ruled that leave encashment received by BSNL retirees is eligible for full exemption under Section 10(10AA).

The Tribunal upheld the CIT(A)'s decision that the reassessment notice was barred by limitation. The reopening was quashed based on the Supreme Court's ruling in Union of India v. Rajeev Bansal.

The Tribunal condoned the delay in filing the appeal and decided to remit the issue of granting 80G approval back to the CIT (Exemptions). The CIT is to decide the matter afresh, treating the application as filed under the correct clause.

The Tribunal condoned the delay, finding the assessee's reasons for delay to be sufficient cause. The matter was restored to the CIT(A) for de novo adjudication on merits, with directions to issue notices to the correct email address.

The Tribunal held that the additional evidence (bank statements) furnished before the CIT(A) needed consideration as it was crucial to the additions made. Therefore, the case was remanded to the CIT(A) to admit the evidence and decide the appeal afresh.

The Tribunal restored the matter to the Assessing Officer (AO) to decide the issue after the application for condonation of delay is disposed of by the competent authority. The AO was directed to take a decision in accordance with law.

The Tribunal condoned the delay in filing the appeal before the CIT(A), finding sufficient cause due to the assessee's non-resident status and reliance on an accountant. The quantum appeal was remanded to the CIT(A) for adjudication on merits.

The Tribunal considered the assessee's request for withdrawal of the appeal. Consequently, the appeal was dismissed as withdrawn.

The Tribunal held that the issue of whether interest income from cooperative banks is deductible under Section 80P(2)(a)(i) or Section 80P(2)(d) is debatable, with conceivably two opinions. Therefore, rectification under Section 154 was not permissible as it requires a mistake apparent from the record.

The Tribunal held that the assessee is entitled to deduction under Section 80P(2)(a)(i) as it is engaged in banking or credit facilities to its members. The interest income earned by the society is attributable to its business activities and therefore eligible for deduction.

The Tribunal upheld the CIT(A)'s decision, allowing the deduction for ESOP expenses based on the jurisdictional High Court's ruling and dismissing the disallowance under Section 14A as no exempt income was earned. Both appeals filed by the Revenue were dismissed.

The Tribunal held that the compensation received under the BSNL VRS Scheme, 2019, qualifies for full exemption under Section 10(10B) of the Income Tax Act, 1961. It also ruled that leave encashment received by BSNL retirees is eligible for full exemption under Section 10(10AA).

The Tribunal held that the compensation received under the BSNL VRS Scheme, 2019, qualifies for exemption under Section 10(10B) of the Income Tax Act, and similarly, leave encashment is also eligible for full exemption. The issue of delay in filing appeals was also condoned on the principle of parity.

The Tribunal held that the compensation received under the BSNL VRS Scheme, 2019, qualifies for exemption under Section 10(10B) of the Income Tax Act, 1961, as retrenchment compensation. It also held that leave encashment is eligible for full exemption under Section 10(10AA).

The Tribunal held that the assessee is entitled to deduction under Section 80P(2)(a)(i) as it is engaged in banking or credit facilities to its members. The interest income earned by the society is attributable to its business activities and therefore eligible for deduction.

The Tribunal held that the CIT(Exemptions) must independently satisfy themselves about the genuineness of activities and compliance with law, and cannot solely rely on recommendations of lower authorities. The CIT(Exemptions) also failed to provide a reasonable opportunity of being heard before rejecting the application.

The Tribunal held that the compensation received under the BSNL VRS Scheme, 2019, qualifies for full exemption under Section 10(10B) of the Income Tax Act, 1961. It also ruled that leave encashment received by BSNL retirees is eligible for full exemption under Section 10(10AA).

The Tribunal held that the compensation received under the BSNL VRS Scheme, 2019, qualifies for full exemption under Section 10(10B) as retrenchment compensation. It also ruled that leave encashment is eligible for full exemption under Section 10(10AA).

The Tribunal held that the compensation received under the BSNL VRS Scheme, 2019, qualifies for full exemption under Section 10(10B) of the Income Tax Act, 1961. It also ruled that leave encashment received by BSNL retirees is eligible for full exemption under Section 10(10AA).

The Tribunal noted that the assessee claimed to have filed a detailed reply with supporting documents, which the CIT(Exemptions) allegedly overlooked. Therefore, the Tribunal decided to restore the issue to the CIT(Exemptions) for fresh consideration.

The Tribunal noted that the assessee claimed to have filed a detailed reply with supporting documents, which the CIT(Exemptions) allegedly overlooked. Therefore, the Tribunal decided to restore the issue to the CIT(Exemptions) for fresh consideration.

The Tribunal held that Section 269ST and Section 271DA were introduced effective from 01.04.2017. Since the transaction occurred before this date, the provisions cannot be applied retrospectively. The penalty was therefore not legally valid.

The Tribunal condoned the 9-day delay in filing the appeal before the CIT(A) due to the assessee's medical issues. The Tribunal directed the CIT(A) to adjudicate the appeal on its merits.

The Tribunal held that the CIT(Exemptions) must independently satisfy themselves about the genuineness of activities and compliance with law, and cannot solely rely on recommendations of lower authorities. The CIT(Exemptions) also failed to provide a reasonable opportunity of being heard before rejecting the application.

The Tribunal held that the interest income earned by the assessee from banks, where members' money was deposited, is attributable to the business of borrowing and lending with members. The Tribunal also found that the disallowance of provision for expenses was unjustified.

The Tribunal admitted additional evidence filed by the assessee and decided to remit the entire issue back to the CIT (Exemptions) for a fresh decision. The CIT (Exemptions) is to consider the additional evidence and grant a reasonable opportunity to the assessee.

The Tribunal restored the matter to the CIT(A) for fresh adjudication on merits. This was due to an inadvertent lapse by the assessee in monitoring email communications, leading to non-submission of details to the CIT(A).

The Tribunal held that the AO and CIT(A) were not justified in sustaining the ad hoc disallowance. The Tribunal noted the absence of evidence showing the reimbursement returning to the assessee or the expenditure being bogus, and that the estimation lacked a rational basis.

The Tribunal held that the ESOP expenses reimbursed by the assessee to its holding company were allowable as business expenditure. This was based on the finding that the expenditure was actually incurred, tax was deducted at source on perquisites to employees, and it pertained to employee compensation.

The Tribunal, in the interest of substantial justice, granted one last opportunity to the assessee to furnish the required documents. The matter was remanded back to the CIT(Exemptions) for fresh consideration.

The Tribunal held that the ESOP expenses reimbursed by the assessee to its holding company were allowable as business expenditure. This was based on the finding that the expenditure was actually incurred, tax was deducted at source on perquisites to employees, and it pertained to employee compensation.

The Tribunal condoned the delay of 72 days, finding the assessee's explanation to be a sufficient cause. The matter was restored to the CIT(A) for adjudication on merits.

The Tribunal, considering the assessee's plea for a last opportunity due to inadvertent non-response, remanded the matter back to the CIT(Exemptions) for fresh consideration. The assessee was cautioned against seeking further adjournments.

The Tribunal held that the ESOP expenses reimbursed by the assessee to its holding company were allowable as business expenditure. This was based on the finding that the expenditure was actually incurred, tax was deducted at source on perquisites to employees, and it pertained to employee compensation.

The Tribunal, in the interest of substantial justice, granted one last opportunity to the assessee to furnish the required documents. The matter was remanded back to the CIT(Exemptions) for fresh consideration.

The Tribunal held that if the duty drawback was indeed taxed in subsequent years, sustaining the addition in the current year would lead to double taxation. The AO was directed to verify this claim.

The Tribunal noted that the assessee has since rectified the defect by executing and registering the lease deed. Therefore, in the interest of justice, the matter was restored to the CIT(E) for fresh adjudication.

The Tribunal, considering the assessee's plea for a last opportunity due to inadvertent non-response, remanded the matter back to the CIT(Exemptions) for fresh consideration. The assessee was cautioned against seeking further adjournments.

The Tribunal admitted additional evidence showing severe personal hardship and litigation faced by the assessee, which constituted a reasonable cause for non-filing. The Tribunal also noted that the penalty was levied under Section 270A, but the AO failed to establish misreporting under Section 270A(9) and the show cause notice was vague. Therefore, the penalty was deleted.

The Tribunal held that the CIT(A) did not pass a reasoned order as mandated by Section 250(6) and that there was sufficient cause for the assessee's non-compliance due to the demise of the consultant. The matter was restored to the CIT(A) for fresh adjudication.

The Tribunal held that the penalty notice issued under Section 274 r.w.s. 270A was invalid as it did not specify the limb of Section 270A under which the penalty was being levied, violating principles of natural justice. Additionally, the belated filing of Form 68 was considered a technical breach that should not deny the assessee immunity from penalty.

The Tribunal held that Section 87A, as applicable for the year, refers to 'total income' and does not contain an express restriction denying rebate on income taxable under Section 111A. The amendment in Finance Act, 2025, was noted as prospective.

The Tribunal held that section 87A rebate is available for income taxable under section 115BAC(1A) even if it includes long-term capital gains taxable under section 112, as there is no express statutory bar for the assessment year in question. The subsequent amendment by the Finance Act, 2025, restricting this rebate, is prospective.

The Tribunal held that the CIT(A) did not pass a reasoned order as mandated by Section 250(6) and that there was sufficient cause for the assessee's non-compliance due to the demise of the consultant. The matter was restored to the CIT(A) for fresh adjudication.