ITAT Bangalore Judgments — June 2026

The Tribunal held that adjustments made by the CPC disallowing employee contributions paid beyond the due dates under respective Acts could not be made under section 143(1) prior to Assessment Year 2021-22. Therefore, the disallowances were directed to be deleted.

The Tribunal held that if the GST component was not debited to the profit and loss account, its refund is merely a recovery of a receivable and not taxable income. The addition was therefore unsustainable.

The Tribunal condoned the delay in filing the appeal, citing genuine and bona fide reasons. The matter was restored to the Assessing Officer for de novo adjudication, with directions for the assessee to furnish supporting details and cooperate with the proceedings.

The Tribunal held that the notice issued under section 148A(b) was not in conformity with the Act as the assessee was not granted the minimum statutory time to respond. Consequently, the reassessment proceedings and the assessment order were quashed.

The Tribunal found the appeal to be defective due to a significant delay, improper filing of Form No. 36, and the absence of a condonation petition. Consequently, the appeal could not be admitted.

The Tribunal held that the penalty under Section 270A was unsustainable because the Assessing Officer failed to specify which clause of Section 270A(9) was attracted and how the assessee's case fell within it. The disallowances made did not, by themselves, establish misreporting of income.

The Tribunal held that adjustments made by the CPC disallowing employee contributions paid beyond the due dates under respective Acts could not be made under section 143(1) prior to Assessment Year 2021-22. Therefore, the disallowances were directed to be deleted.

The Tribunal held that the Assessing Officer failed to record the necessary satisfaction after examining the assessee's accounts before invoking Section 14A and Rule 8D. Therefore, the disallowance beyond the assessee's voluntary amount was unsustainable.

The Tribunal held that the hulling/curing charges were genuine business expenses incurred for processing coffee beans and directed their deletion. It also found that the agricultural expenses were sufficiently substantiated with evidence and directed the deletion of the ad hoc disallowance.

The Tribunal held that the Dispute Resolution Panel's direction to delete an addition of ₹3,28,25,770 was a typographical error and intended to delete the entire addition of ₹3,38,25,770. Therefore, the remaining addition of ₹10,00,000 should also be deleted.

The Tribunal held that while CSR expenditure is not allowable as business expenditure, there is no bar to claiming deduction under Section 80G if donations are made to eligible institutions. The disallowance of employees' PF contribution was upheld based on a Supreme Court decision.

The Tribunal held that the collection of 'development fees' was not necessarily indicative of a profit motive and that the reinvestment of compensation for compulsory acquisition of property into new capital assets met the conditions of Section 11(1A) of the Income Tax Act.

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal held that the assessee had established a cash balance from previous withdrawals, and since there was no contra-evidence, the addition under Section 69A was deleted. Consequently, the issue of higher tax rate became moot.

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal held that the assessee's claim was inadvertent and not intentional, and the revenue failed to establish the conditions for levying penalty under Section 270A. Therefore, the penalty was directed to be deleted.

The Tribunal held that the collection of 'development fees' was not necessarily indicative of a profit motive and that the reinvestment of compensation for compulsory acquisition of property into new capital assets met the conditions of Section 11(1A) of the Income Tax Act.

The Tribunal condoned the delay in filing the appeals and set aside the ex-parte orders of the CIT(A). The issues were restored to the file of the CIT(A) for adjudication on merits, subject to the assessee paying costs.

The Tribunal found that the assessee had sufficient cause for the delay in filing the appeal before the CIT(A) due to hospitalization. Therefore, the order of the CIT(A) dismissing the appeal on limitation grounds was set aside.

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal held that the collection of 'development fees' was not necessarily indicative of a profit motive and that the reinvestment of compensation for compulsory acquisition of property into new capital assets met the conditions of Section 11(1A) of the Income Tax Act.

The Tribunal held that the collection of 'development fees' was not necessarily indicative of a profit motive and that the reinvestment of compensation for compulsory acquisition of property into new capital assets met the conditions of Section 11(1A) of the Income Tax Act.

The Tribunal directed the Assessing Officer to reduce the double addition of realized income. It also restored the issue of mine development expenditure disallowed in an earlier year due to non-deduction of TDS to the Assessing Officer for verification and potential allowance in the current year.

The Tribunal condoned the delay in filing the appeals and set aside the ex-parte orders of the CIT(A). The issues were restored to the file of the CIT(A) for adjudication on merits, subject to the assessee paying costs.

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal condoned the delay in filing the appeals and set aside the ex-parte orders of the CIT(A). The issues were restored to the file of the CIT(A) for adjudication on merits, subject to the assessee paying costs.

The Tribunal held that the assessee had established a cash balance from previous withdrawals, and since there was no contra-evidence, the addition under Section 69A was deleted. Consequently, the issue of higher tax rate became moot.

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal upheld the CIT(A)'s decision, stating that the AO failed to provide cogent reasons for not accepting the assessee's explanation. Since the entire sales were declared by the firm, the purchases should also be accounted for in the firm's hands.

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal directed the Assessing Officer to reduce the double addition of realized income. It also restored the issue of mine development expenditure disallowed in an earlier year due to non-deduction of TDS to the Assessing Officer for verification and potential allowance in the current year.

The Tribunal held that the CIT(A) ought to have condoned the delay in filing appeals, considering numerous similar cases where delays were condoned and exemptions were granted. The Tribunal allowed exemption for retrenchment compensation under Section 10(10B) and entire leave encashment under Section 10(10AA).

The Tribunal found that the credits were from customers for tyre sales and the advance payment was for tyre purchases. Therefore, the entire amount should not be treated as unexplained income. The Tribunal estimated the profit on these transactions at 8%.

The Tribunal noted that the AO had not properly considered the assessee's explanation and supporting documents. Citing a previous order where a similar delay was condoned, the Tribunal decided to remit the appeal back to the AO for a fresh consideration.

The Tribunal held that additions made on account of cash deposits and difference in VAT sales were unsustainable. The assessee had provided sufficient evidence like ledger accounts and sample bills to support the cash receipts from sundry debtors.

The Tribunal held that the cash deposited was largely from earlier withdrawals from the same bank account and thus available for redeposit. A small portion of the deposit, Rs. 3,85,485, was considered potentially not sourced from withdrawals, but this amount could be financed by the husband's substantial income.

The Tribunal held that Section 14A disallowance cannot be made if the assessee has not earned any exempt income. For additions made in the intimation under Section 143(1), the Tribunal directed the assessee to file a fresh appeal before the first appellate authority.

The Tribunal held that the reasons provided by the assessee do not constitute a 'sufficient cause' for the inordinate delay. The Tribunal noted that the assessee was aware of separate proceedings and the reasons were mere excuses, not explanations.

The Tribunal restored the issue of additions made for payments to SUN Direct TV and M/s S.V. Enterprises to the Assessing Officer for fresh verification. The assessee needs to provide details to support the claim that these amounts belonged to his mother's business.

The Tribunal condoned the delay of 221 days, holding that the assessee had sufficient cause and that substantial justice should be preferred over technicalities. The adjustment made by the CPC regarding employees' contribution to provident fund/ESI deposited beyond the due date prior to AY 2021-22 was directed to be deleted.

The Tribunal held that the cash deposits were out of sale proceeds and taxing them again would amount to double taxation. The Tribunal also found the Rs. 12,00,000 cash deposit explained by the assessee's submission of a confirmation letter and related documents.

The Tribunal admitted additional evidence of bank statements and found that the lower authorities had not properly verified the cash book against bank transactions. Therefore, the issue was restored to the Assessing Officer for de novo adjudication.

The Tribunal held that the assessee had sufficient interest-free funds (share capital and reserves) to cover its investments in the subsidiary. Therefore, it was presumed that the investments were made from these own funds, not borrowed ones.

The Tribunal held that the transfer pricing adjustment, initially confirmed at ₹ 16,983,460 by the TPO in the order giving effect to the DRP's directions and subsequently carried into the final assessment order, had been reduced to ₹ Nil by a subsequent rectification order dated 27 March 2026. The Tribunal found that the entire addition originally made now stood reduced to nil. Therefore, the Tribunal directed the learned Assessing Officer to pass a rectification order, adopting the arm's-length price determined by the TPO and reducing the transfer pricing adjustment to ₹ Nil. The AO was further directed to make corresponding rectification in the final assessment order and determine the assessee's total income at the returned income within 30 days. The Tribunal noted that the assessee had already made a request for rectification on 1 April 2026, but the consequential order had not yet been passed. The ratio decidendi is that where a subsequent rectification order by the TPO reduces an addition to nil, the AO must give effect to it, rendering the appeal against the original addition infructuous.