ITAT Bangalore Judgments — May 2026

The Tribunal held that the Assessing Officer made the addition without checking evidence that the withdrawn cash was spent. The source of the deposit was the prior withdrawal from the same account, making the addition u/s 68 unwarranted.

The Tribunal held that the indexation benefit for the township sale should be allowed from FY 2008-09 as the property was earning rental income then. For the AIF units, the Tribunal found no infirmity in the CIT(A)'s deletion of the addition, as the valuation method was consistent and the loss was explained.

The Tribunal found that the CIT(A) passed a non-speaking order without providing a reasonable opportunity to the assessee, despite the assessee's lack of cooperation with the AO. The case was set aside and remitted to the AO for fresh consideration.

The Tribunal held that once a substantive addition is confirmed in the hands of the partner, a protective addition in the hands of the firm should be deleted. The Revenue failed to pursue both matters concurrently.

The Tribunal held that the assessee had explained the sources of unsecured loans by demonstrating that loans were taken from sons, Abhishek and Akhilesh, which were disclosed in earlier financial statements. The AO failed to consider the opening balance of unsecured loans from these sons.

The Tribunal found that the assessee had indeed submitted the required details to the Income Tax Officer as directed. Therefore, the CIT(E)'s rejection based on non-compliance was incorrect.

The Tribunal held that bonus shares, even if issued on shares held as stock-in-trade, can be treated as capital assets if the assessee intends to hold them as such and discloses them as investments. The Tribunal relied on CBDT circulars and Supreme Court judgments to support this.

The Tribunal condoned the delay in filing appeals before the CIT(A) as the assessee had a valid reason due to a change in PAN. The appeals were restored to the CIT(A) for fresh consideration on merits.

The Tribunal condoned the delay in filing the appeal due to bona fide reasons. Considering the assessee's circumstances and the ex-parte assessment, the Tribunal restored the issue to the AO for fresh adjudication.

The Tribunal condoned the delay in filing the appeal, citing sufficient cause and the principle of substantial justice. The appeal was admitted for adjudication on its merits.

The Tribunal set aside the ex-parte orders of the CIT(A) on the condition that the assessee pays a cost of Rs. 11,000 each to the Prime Minister's National Relief Fund. The appeals were allowed for statistical purposes.

The Tribunal set aside the ex-parte orders of the CIT(A) on the condition that the assessee pays a cost of Rs. 11,000 each to the Prime Minister's National Relief Fund. The appeals were allowed for statistical purposes.

The Tribunal held that the seized materials, consisting of loose sheets and uncorroborated jottings, lacked evidentiary value and were not sufficient to make additions. The assessee was also denied the opportunity for cross-examination.

The Tribunal held that the seized materials, consisting of loose sheets and uncorroborated jottings, lacked evidentiary value and were not sufficient to make additions. The assessee was also denied the opportunity for cross-examination.

The Tribunal held that the seized materials, consisting of loose sheets and uncorroborated jottings, lacked evidentiary value and were not sufficient to make additions. The assessee was also denied the opportunity for cross-examination.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to notices going to the spam folder. The case was set aside and remitted to the AO for fresh consideration, allowing the assessee to furnish documents.

The Tribunal condoned the delay in filing the appeal, acknowledging the assessee's explanation regarding an outdated email address. It found that the AO and CIT(A) had not examined the source of funds for the cash withdrawals, which the assessee claimed was partner capital contributions.

The Tribunal held that the reasons provided for the delay were general and did not establish a sufficient cause for not filing the appeal within the prescribed period. Therefore, the appeal was not admitted.

The Tribunal restored the issue of lease receipt of Rs. 20 lakhs to the AO for fresh examination with additional evidence. However, it directed the AO to allow the remaining agricultural income of Rs. 8,12,700/- as claimed by the assessee.

The Tribunal held that the seized materials, consisting of loose sheets and uncorroborated jottings, lacked evidentiary value and were not sufficient to make additions. The assessee was also denied the opportunity for cross-examination.

The Tribunal condoned the delay in filing the appeal due to the assessee's age and bona fide reasons. The case was restored to the Assessing Officer for fresh adjudication after the assessee provides necessary evidence.

The Tribunal condoned the delay of 73 days in filing the appeal before the CIT(A), finding valid explanations for the delay. The issue was remitted to the CIT(A) for fresh consideration.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to the assessee being a housewife with no email access. The case was remitted to the AO for fresh consideration, allowing the assessee to produce documents.

The Tribunal held that the assessee had sufficiently explained the receipt of Rs. 36.62 lakh as a gift from her brother, which originated from the sale of agricultural land. Consequently, the cash deposits of Rs. 23.50 lakh during demonetisation were also considered explained.

The Tribunal held that interest income earned by the cooperative society from deposits, which were essentially surplus funds not immediately required for lending, is attributable to its primary business of providing credit facilities. The Tribunal also found that disallowance of expense provisions was not justified as they were made on an accrual basis.

The Tribunal held that interest income earned by the cooperative society from deposits, which were essentially surplus funds not immediately required for lending, is attributable to its primary business of providing credit facilities. The Tribunal also found that disallowance of expense provisions was not justified as they were made on an accrual basis.

The Tribunal held that interest income earned by the cooperative society from deposits, which were essentially surplus funds not immediately required for lending, is attributable to its primary business of providing credit facilities. The Tribunal also found that disallowance of expense provisions was not justified as they were made on an accrual basis.

The Tribunal held that the AO exceeded the scope of limited scrutiny by making additions for cash deposits outside the demonetization period without prior approval. The Tribunal also noted discrepancies in the amount of cash deposits calculated by the AO and the assessee.

The Tribunal found that the Department failed to show sufficient cause for the delay in filing the appeal. Therefore, the Tribunal did not admit the appeal.

The Tribunal held that for projects under the project completion method, disallowances under Section 40(a)(ia) should reduce WIP rather than being added to income, unless the project is completed. The matter was remanded to the AO for verification.

The Tribunal held that the AO was justified in treating the purchases as bogus due to the assessee's failure to prove their genuineness. The assessee's books of accounts were deemed unreliable, leading to the addition of unexplained bogus purchases.

The Tribunal held that the sanction for reopening beyond three years must be obtained from the Principal Chief Commissioner or Chief Commissioner, as mandated by Section 151(ii). Approval from an inferior authority renders the reassessment proceedings void ab initio.

The Tribunal held that the CIT(Exemptions) was obligated to consider the documents filed by the assessee. The matter was remitted back to the CIT(Exemptions) for fresh adjudication after considering the submitted documents and providing an opportunity of hearing.

The Tribunal held that penalty under Section 271AAC is not automatic and requires discretion, especially since penalty proceedings are quasi-criminal. The assessee had recorded unsecured loans in their books, and while details were not fully provided, it constituted a technical breach rather than concealment, warranting deletion of the penalty.

The Tribunal, considering the assessee's willingness to furnish evidence and the interest of substantial justice, set aside the lower authorities' orders and restored the issue to the AO for fresh adjudication. This was subject to the assessee depositing Rs. 11,000/- to the Prime Minister National Relief Fund.

The Tribunal noted that the assessee is a religious organization and that the CIT(Exemptions) had also acknowledged its religious character. The Tribunal found that the CIT(Exemptions) could have granted registration as a religious trust. The financial transactions were deemed to be a matter for the Assessing Officer during assessment.

The Tribunal found the assessee's reasons for the delay to be genuine and granted an opportunity to present her case on merits. The delay in filing the appeal before the CIT(A) was condoned.

The Tribunal held that the adjustment made under Section 143(1) for delayed deposit of employee contributions to PF & ESI was not permissible prior to AY 2021-22. The Tribunal noted that the Supreme Court decision in Checkmate Services was rendered after the intimation was passed, and at that time, the Karnataka High Court's view favored the assessee.

The Tribunal condoned the delay of 8.5 years, considering the assessee's reasonable cause and the department's prolonged inaction. The Tribunal emphasized preferring substantial justice over technicalities, citing Apex Court judgments.

The Tribunal held that the systematic instruction in Arabic language and Islamic studies, when done academically, constitutes education and not religious activity. The dominant objective of the trust was found to be educational and charitable, serving the public in general.

The Tribunal held that the assessee is eligible for deduction under Section 80P(2)(a)(i) of the Income Tax Act, 1961, in respect of income attributable to 'C' class (nominal) members. The Tribunal distinguished the present case from the Supreme Court's decision in Citizen Co-operative Society Ltd. by noting that the assessee society is governed by the Karnataka Co-operative Societies Act, 1959, and its approved bye-laws, which explicitly recognize nominal and associate members. The Tribunal found that the assessee strictly adheres to statutory provisions, does not deal with non-members, has no regulatory breaches, and maintains mutuality. The Tribunal also referred to the jurisdictional High Court of Karnataka's decision in Tumkur Merchants Souharda Credit Cooperative Ltd., which held that interest income earned by a cooperative society from temporarily parking surplus funds with banks is attributable to its business and eligible for deduction under Section 80P(2)(a)(i). The Tribunal distinguished the Karnataka High Court's decision in BELVE VYAVASAYA SEVA SAHAKARI SANGHA LTD vs. ITO, which dealt with deduction under Section 80P(2)(d) concerning investments with cooperative banks, from the present case concerning deduction under Section 80P(2)(a)(i) for income from its primary business of providing credit facilities. The AO was directed to delete the addition made. The Tribunal also noted that grounds related to general issues and interest under Section 234B were dismissed as infructuous or general.

The Tribunal held that the assessee is eligible for deduction under Section 80P(2)(a)(i) of the Income Tax Act, 1961, in respect of income attributable to 'C' class (nominal) members. The Tribunal distinguished the present case from the Supreme Court's decision in Citizen Co-operative Society Ltd. by noting that the assessee society is governed by the Karnataka Co-operative Societies Act, 1959, and its approved bye-laws, which explicitly recognize nominal and associate members. The Tribunal found that the assessee strictly adheres to statutory provisions, does not deal with non-members, has no regulatory breaches, and maintains mutuality. The Tribunal also referred to the jurisdictional High Court of Karnataka's decision in Tumkur Merchants Souharda Credit Cooperative Ltd., which held that interest income earned by a cooperative society from temporarily parking surplus funds with banks is attributable to its business and eligible for deduction under Section 80P(2)(a)(i). The Tribunal distinguished the Karnataka High Court's decision in BELVE VYAVASAYA SEVA SAHAKARI SANGHA LTD vs. ITO, which dealt with deduction under Section 80P(2)(d) concerning investments with cooperative banks, from the present case concerning deduction under Section 80P(2)(a)(i) for income from its primary business of providing credit facilities. The AO was directed to delete the addition made. The Tribunal also noted that grounds related to general issues and interest under Section 234B were dismissed as infructuous or general.

The Tribunal held that the systematic instruction in Arabic language and Islamic studies, when done academically, constitutes education and not religious activity. The dominant objective of the trust was found to be educational and charitable, serving the public in general.

The Tribunal held that the assessee failed to provide sufficient and cogent reasons to condone the inordinate delay. The reasons provided were considered excuses rather than explanations, and the law of limitation was emphasized.

The Tribunal condoned the delay of 35 days, finding sufficient cause for the late filing due to the tax practitioner's negligence. Additional evidence submitted by the assessee was also admitted.

The Tribunal condoned the delay in filing appeals, set aside the ex-parte orders, and remitted the quantum addition issue to the AO for fresh consideration. The penalty for non-compliance was deleted, accepting the assessee's explanation of incorrect address.

The Tribunal condoned the delay in filing appeals, set aside the ex-parte orders, and remitted the quantum addition issue to the AO for fresh consideration. The penalty for non-compliance was deleted, accepting the assessee's explanation of incorrect address.