ITAT Bangalore Judgments — June 2026

The Tribunal held that the excess cash and stock found during the survey should be treated as business income, not unexplained investment, as the assessee had disclosed it as business income and there was no evidence of any other source of income. Consequently, Section 115BBE was not applicable.

The Tribunal held that the actual cost of acquisition should be considered, not the lower value in the sale deed, as the assessee provided sufficient evidence of payment. The Tribunal also directed that 100% of the cost of improvement should be allowed, as this was not an issue in the earlier round of litigation.

The Tribunal held that the AO erred in adopting the builder's cost of construction as the sale consideration. It noted that the assessee's reliance on judicial precedents where the revenue's approach was rejected was relevant, and the AO's attempt to distinguish the cases based on the availability of verifiable data was not sufficiently established.

The Tribunal held that the AO erred in adopting the builder's cost of construction as the sale consideration. It noted that the assessee's reliance on judicial precedents where the revenue's approach was rejected was relevant, and the AO's attempt to distinguish the cases based on the availability of verifiable data was not sufficiently established.

The Tribunal held that if a working capital adjustment is granted, a separate adjustment for interest on overdue receivables is unwarranted. The case was restored to the AO/TPO to decide the working capital adjustment issue afresh, considering the burden of proof lies with the revenue authorities when they select comparables.

The Tribunal accepted the assessee's request for withdrawal of the appeal. The reasoning was based on the assessee's submission that the grounds of appeal, specifically those relating to transfer pricing adjustments, were now covered by the Advance Pricing Agreement (APA) entered into with the CBDT on 25.03.2026. The Tribunal found this submission to be valid and acceded to the request. Consequently, the appeal filed by the assessee was dismissed as withdrawn. No specific findings were made on the merits of the transfer pricing adjustments themselves, as the appeal was disposed of on a procedural basis. The operative direction was to dismiss the appeal as withdrawn.

The Tribunal held that the presence of nominal members does not disentitle the assessee to deduction under Section 80P(2)(a)(i). It also stated that a multipurpose cooperative society is not restricted from claiming this deduction. The Tribunal found the orders of lower authorities needed revisiting.

The Tribunal held that the AO's final assessment order was not in conformity with the DRP's directions, violating Section 144C(13) of the Act. The final assessment order was quashed.

The Tribunal held that the presence of nominal members does not disentitle the assessee to deduction under Section 80P(2)(a)(i). It also stated that a multipurpose cooperative society is not restricted from claiming this deduction. The Tribunal found the orders of lower authorities needed revisiting.

The Tribunal held that the presence of nominal members does not disentitle the assessee to deduction under Section 80P(2)(a)(i). It also stated that a multipurpose cooperative society is not restricted from claiming this deduction. The Tribunal found the orders of lower authorities needed revisiting.

The Tribunal held that the presence of nominal members does not disentitle the assessee to deduction under Section 80P(2)(a)(i). It also stated that a multipurpose cooperative society is not restricted from claiming this deduction. The Tribunal found the orders of lower authorities needed revisiting.

The Tribunal restored the matter to the Assessing Officer for fresh adjudication after the condonation petition is decided. If the delay is condoned, the assessee may become eligible for the deduction.

The Assessing Officer (AO) passed the final assessment order without conforming to the DRP's directions, which was found to be in violation of Section 144C(13). The Tribunal quashed the final assessment order.

The Tribunal held that the notice issued under Section 148 of the Income Tax Act was barred by limitation as it was issued beyond the prescribed time limit. Consequently, the reassessment order and the order under Section 148A(d) were quashed.

The Tribunal held that expenses incurred for raising share capital, even for working capital, are capital in nature and not deductible, following a Supreme Court decision. Other grounds related to penalty proceedings were dismissed as premature or general.

The Tribunal accepted the assessee's request for withdrawal of the appeal, as communicated vide the letter dated 02.06.2026. The reasoning was that the grounds of appeal concerning transfer pricing adjustments were now covered by an Advance Pricing Agreement (APA) entered into by the assessee with the CBDT on 25.03.2026. Consequently, the Tribunal dismissed the present appeal as withdrawn. No specific issue was left undecided, as the appeal was withdrawn by the assessee.

The Tribunal held that the notice issued under Section 148 of the Income Tax Act was barred by limitation as it was issued beyond the prescribed time limit. Consequently, the reassessment order and the order under Section 148A(d) were quashed.

The Tribunal held that the payment of the bonus made in the current year for a prior year's disallowance is allowable as a deduction under Section 43B. The inconsistency in the tax audit report should not lead to disallowance when actual payment is evidenced.

The Tribunal held that the explanation of cash withdrawals from earlier years cannot be rejected solely on the basis of a time gap, without contrary evidence from the Revenue. The Revenue must disprove the withdrawals or show the money was utilized elsewhere.

The Tribunal noted that the assessee claimed the payments were inadvertently recorded as cash and were actually made through banking channels, with subsequent corrections. To ensure justice and fair play, the issue was remitted back to the CIT(A)/NFAC for a fresh decision.

The tribunal held that the notices issued under section 148A(b) were invalid as they did not provide the mandatory minimum period of seven days for the assessee to reply. Consequently, the reassessment proceedings and the assessment order were quashed.

The Tribunal decided to remit the appeals back to the PCIT(A) for fresh consideration. The assessee was directed to provide all relevant documents and evidence, and granted an opportunity to be heard.

The Tribunal considered the assessee's request to withdraw the appeal. Since the assessment proceedings were restored to the Assessing Officer, the appeal was dismissed as withdrawn.

The assessee requested to withdraw the appeal as the issue was covered by a Unilateral Advance Pricing Arrangement (UAPA) entered into with the CBDT. The Tribunal accepted the request and dismissed the appeal.

The Tribunal held that in the interest of justice, the assessee should be granted one more opportunity to present its case on merits before the Ld. CIT(A). The Tribunal noted that the Ld. CIT(A) had passed the order ex parte due to non-compliance with hearing notices, which the assessee attributed to notices being sent to an incorrect email address. The Ld. AR undertook to attend to hearing notices sent to the email address rakshithg24@gmail.com, which is a recent address. The Tribunal directed the assessee to update its details with the Ld. CIT(A) and appear on all future hearing dates without default. Consequently, the appeals were restored to the file of the Ld. CIT(A) for de novo adjudication on merits. The other grievances raised by the assessee in the present appeals were not adjudicated at this stage. The grounds raised by the assessee were allowed for statistical purposes.

The Tribunal held that in the interest of justice, the assessee should be granted one more opportunity to present its case on merits before the Ld. CIT(A). The Tribunal noted that the Ld. CIT(A) had passed the order ex parte due to non-compliance with hearing notices, which the assessee attributed to notices being sent to an incorrect email address. The Ld. AR undertook to attend to hearing notices sent to the email address rakshithg24@gmail.com, which is a recent address. The Tribunal directed the assessee to update its details with the Ld. CIT(A) and appear on all future hearing dates without default. Consequently, the appeals were restored to the file of the Ld. CIT(A) for de novo adjudication on merits. The other grievances raised by the assessee in the present appeals were not adjudicated at this stage. The grounds raised by the assessee were allowed for statistical purposes.

The Tribunal held that in the interest of justice, the assessee should be granted one more opportunity to present its case on merits before the Ld. CIT(A). The Tribunal noted that the Ld. CIT(A) had passed the order ex parte due to non-compliance with hearing notices, which the assessee attributed to notices being sent to an incorrect email address. The Ld. AR undertook to attend to hearing notices sent to the email address rakshithg24@gmail.com, which is a recent address. The Tribunal directed the assessee to update its details with the Ld. CIT(A) and appear on all future hearing dates without default. Consequently, the appeals were restored to the file of the Ld. CIT(A) for de novo adjudication on merits. The other grievances raised by the assessee in the present appeals were not adjudicated at this stage. The grounds raised by the assessee were allowed for statistical purposes.

The Tribunal considered the assessee's request for withdrawal based on the BAPA. The grounds of appeal were covered under the BAPA.

The Tribunal condoned the delay in filing the appeal due to issues with communication of the CIT(A)'s order. It was held that the assessee was prevented from presenting their case properly before the lower authorities.

The Tribunal held that the sale of shares and the purchase of the property were independent transactions. It found no evidence to establish the transactions as sham and accepted the inclusion of certain charges in the cost of the new asset for deduction purposes.

The Tribunal decided to remit the appeals back to the PCIT(A) for fresh consideration. The assessee was directed to provide all relevant documents and evidence, and granted an opportunity to be heard.

The Tribunal held that the CIT(Exemptions) erred in rejecting the application without adhering to the principles of natural justice. The assessee should have been given an opportunity to rectify the mistake or present their case.

The Tribunal held that in the interest of justice, the assessee should be granted one more opportunity to present its case on merits before the Ld. CIT(A). The Tribunal noted that the Ld. CIT(A) had passed the order ex parte due to non-compliance with hearing notices, which the assessee attributed to notices being sent to an incorrect email address. The Ld. AR undertook to attend to hearing notices sent to the email address rakshithg24@gmail.com, which is a recent address. The Tribunal directed the assessee to update its details with the Ld. CIT(A) and appear on all future hearing dates without default. Consequently, the appeals were restored to the file of the Ld. CIT(A) for de novo adjudication on merits. The other grievances raised by the assessee in the present appeals were not adjudicated at this stage. The grounds raised by the assessee were allowed for statistical purposes.

The Tribunal found that the assessee had provided substantial documentation for unsecured loans and explained cash deposits as sales collections. The lower authorities had not properly verified these details.

The Tribunal found that the assessee made payments through banking channels for amounts exceeding Rs. 20,000 and incurred other expenses within the prescribed limits under Section 40A(3). The estimation of book profit was also deemed unsustainable as the audited books were not rejected.

The Tribunal allowed the appeal regarding the ex gratia payment provision, holding it was an ascertained liability. It also deleted the disallowance under Section 14A due to the Assessing Officer's lack of satisfaction, and allowed the appeal concerning expenditure on share capital increase.

The Tribunal allowed the appeal regarding the ex gratia payment provision, holding it was an ascertained liability. It also deleted the disallowance under Section 14A due to the Assessing Officer's lack of satisfaction, and allowed the appeal concerning expenditure on share capital increase.

The Tribunal held that if the capital gains are utilized for construction before filing the return under Section 139(4), the assessee is entitled to the deduction under Section 54, even if the deposit was not made before the original due date under Section 139(1).

The Tribunal held that the assessee is a public charitable trust and not a discretionary trust. Since the members/trustees are not entitled to any share of the income, section 164(1) is not attracted, and tax should be levied at normal rates.

The Tribunal held that the assessee is entitled to deduction for bad debts written off as per Section 36(1)(vii) as it was sufficiently evidenced by the ledger accounts. The Tribunal also deleted the arbitrary disallowance of expenses made by the lower authorities.

The Tribunal held that the applicability of Section 44AB depends on the correct computation of gross receipts. The Tribunal noted that the assessee's contention regarding the definition of gross receipts and the inclusion of loan recoveries in bank deposits needed proper adjudication. The penalty proceedings were considered premature without a final determination of the gross receipts.

The Tribunal held that the AO's addition of share capital as unexplained credit under Section 68 was justified. The investor companies failed to prove their creditworthiness and the genuineness of the transactions, especially given the losses incurred and the nature of their operations.

The Tribunal dismissed the appeals as infructuous. This was based on the High Court setting aside the assessment orders under Section 147, rendering the appeals before the Tribunal moot.

The Tribunal dismissed the appeals as infructuous. This was based on the High Court setting aside the assessment orders under Section 147, rendering the appeals before the Tribunal moot.

The Tribunal held that the CIT(A) should have been liberal in admitting additional evidence to arrive at a correct computation of income. The Tribunal set aside the CIT(A)'s order regarding the rejection of the application and remitted the issue back for fresh adjudication.

The Tribunal held that the appeal is not maintainable because the defects, as per the Defect Memo issued on 16th January 2026, were not cured by the Assessee's counsel. The Tribunal relied on the provisions of Rule 4A(2)(iv) of the ITAT Rules. The reasoning is that non-compliance with the procedural requirements for filing an appeal renders it invalid. Therefore, the appeal was returned to the Assessee with a liberty to file a fresh appeal. No specific amount in dispute or substantive issues of the assessment were decided.

The Tribunal held that interest income earned by the co-operative society from deposits with co-operative banks is attributable to its business of providing credit facilities to its members and is eligible for deduction under Section 80P(2)(a)(i).

The Tribunal dismissed the appeals as infructuous. This was based on the High Court setting aside the assessment orders under Section 147, rendering the appeals before the Tribunal moot.

The Tribunal held that interest income earned by a co-operative society from deposits with co-operative banks, when not immediately required for lending to members, is attributable to its business of providing credit facilities and thus eligible for deduction under Section 80P(2)(a)(i).

The Tribunal dismissed the appeals as infructuous. This was based on the High Court setting aside the assessment orders under Section 147, rendering the appeals before the Tribunal moot.