ITAT Bangalore Judgments — July 2026

The Tribunal found that the evidence submitted by the assessee, including purchase bills for seeds and sale bills for onions, had not been fully examined by the lower authorities. Therefore, the matter was restored to the AO for de novo adjudication.

The Tribunal found that the CIT(Exemptions) had not properly considered the assessee's submissions and had denied a reasonable opportunity of being heard. The Tribunal remitted the matters back to the CIT(Exemptions) for fresh consideration.

The Tribunal condoned the delay in filing the appeal, finding sufficient cause. Considering the assessee's illiteracy and inability to represent themselves effectively, the Tribunal remitted the entire issue back to the Assessing Officer for fresh adjudication.

The Tribunal condoned the delay in filing the appeal before the CIT(A), stating that procedural rules should not impede substantial justice. The impugned order of the CIT(A) was set aside, and the appeal was restored for de novo consideration.

The Tribunal found that the CIT(A)'s order was passed in violation of natural justice due to the technical issue and lack of proper opportunity. Therefore, the case was remitted back to the CIT(A) for fresh adjudication.

The Tribunal condoned the delay in filing the appeal due to the assessee's health issues. The Tribunal decided to remit the entire issues in dispute back to the Assessing Officer for a fresh adjudication.

The Tribunal found it appropriate to remit the entire issue to the AO for a fresh decision, granting the assessee a reasonable opportunity to be heard and to produce necessary documents.

The Tribunal found that the CIT(Exemptions) had not properly considered the assessee's submissions and had denied a reasonable opportunity of being heard. The Tribunal remitted the matters back to the CIT(Exemptions) for fresh consideration.

The Tribunal condoned the significant delay in filing the appeal, finding sufficient cause due to the confluence of personal issues, pandemic, and portal difficulties. The issue of foreign tax credit was restored to the Assessing Officer for fresh examination.

The Tribunal noted that while the assessee was non-compliant during assessment, it has now provided detailed documentation. Since these documents were not verified by lower authorities, the matter was restored to the AO for de novo consideration.

The Tribunal noted that the assessee could not represent his case before the CIT(A) despite opportunities. The assessee's representative undertook to file explanations and documents if the case was remitted. The Tribunal decided to remit the issues back to the CIT(A) for fresh consideration.

The Tribunal condoned the 36-day delay in filing the appeal before the CIT(A), finding sufficient cause. The Tribunal then remitted the entire issue of exemption claimed under Section 54 back to the Assessing Officer for fresh adjudication.

The Tribunal restored the issue to the file of the AO for fresh adjudication, granting the assessee one more opportunity to be heard. A token cost of Rs. 1,000 was imposed on the assessee for continuous negligence.

The Tribunal, in the interest of justice, decided to remit the entire issues back to the CIT(A) for fresh consideration. The assessee was granted a reasonable opportunity to present their case with supporting evidence.

The Tribunal condoned the delay, finding sufficient cause for the late filing. It then remitted the matter back to the CIT(A)/NFAC for a fresh decision on merits, as the Vivad se Vishwas settlement did not materialize.

The Tribunal held that a demand notice and computation sheet are consequential documents and cannot introduce new tax liabilities or amounts not explicitly found in the assessment order. Since the assessment order accepted the returned income without additions, the subsequent demand was unsustainable.

The Tribunal held that if the Assessing Officer finds that the cash deposits belonged to the mother-in-law and were accounted for by her, no addition is warranted in the assessee's hands. The matter was restored to the Assessing Officer for verification.

The Tribunal noted that the Assessee's appeal was filed against an assessment order dated December 30, 2025, which determined the total income at ₹9,50,92,840, including a transfer pricing adjustment of ₹2,40,24,687. However, subsequent to the filing of the appeal, the Dispute Resolution Panel (DRP) issued rectified directions on February 26, 2026. The Transfer Pricing Officer (TPO) gave effect to these rectified directions on March 11, 2026, resulting in a revised transfer pricing adjustment of Nil. The Assessing Officer (AO) then passed a final order on June 17, 2026, accepting the Assessee's returned income of ₹7,10,68,153. Consequently, the Tribunal found that all grounds raised by the Assessee had become infructuous in light of the AO's final order accepting the returned income. The principle established is that if subsequent events render the grounds of appeal moot, the appeal becomes infructuous. The operative direction was to dismiss the appeal as infructuous.

The Tribunal found that the assessee could not properly represent its case before the lower authorities. Therefore, in the interest of justice, the matter was remitted back to the Assessing Officer for a fresh decision.

The Tribunal condoned the delay in filing the appeal, prioritizing substantial justice over technicalities. The issue of the business loss being wrongly treated as income was remitted to the Assessing Officer for fresh examination.

The Tribunal held that the PCIT erred in invoking Section 263 as the assessment order was neither erroneous nor prejudicial to the interest of the revenue. The AO had taken a plausible view, and the PCIT cannot substitute his own opinion for that of the AO when two views are possible.

The Tribunal held that the assessee's claim falls under Section 80P(2)(a)(i) as its core activity involves providing credit facilities to members. Income earned from investing surplus funds, which is necessary to safeguard member deposits and meet withdrawal demands, is part of this core activity.

The Tribunal held that the amount received on repurchase of stock options is not taxable as perquisites under 'Salaries'. Reliance on Form 16 and the offer letter was deemed insufficient to determine taxability.

The Tribunal held that the CIT(A) is duty-bound to adjudicate an appeal on merits and cannot dismiss it solely for non-prosecution. The CIT(A) must pass a reasoned order and cannot mechanically affirm the Assessing Officer's order.

The assessee subsequently sought to withdraw its appeal against the CIT's order. The Tribunal permitted the withdrawal of the appeal.

The Tribunal held that the assessee is a co-operative society engaged in providing credit facilities to its members and not a co-operative bank, thus Section 80P(4) is not attracted. It also held that the addition under Section 68 for cash deposits was unwarranted as the source was explained.

The Tribunal held that the assessee's claim falls under Section 80P(2)(a)(i) as its core activity involves providing credit facilities to members. Income earned from investing surplus funds, which is necessary to safeguard member deposits and meet withdrawal demands, is part of this core activity.

The Tribunal held that the interest income earned by the credit co-operative society on deposits made for its business purposes is attributable to its business of providing credit facilities. Therefore, it is eligible for deduction under Section 80P(2)(a)(i).

The Tribunal held that the assessee failed to satisfactorily explain the source and acquisition of the jewellery. Aggregating family income over several years was not sufficient to justify the unexplained jewellery.

The Tribunal condoned the delay in filing the appeal before the CIT(A) after finding sufficient cause. The Tribunal also decided to remit the entire issue back to the Assessing Officer for fresh adjudication on merits, granting the assessee a reasonable opportunity to be heard and submit documents.

The Tribunal permitted the assessee to withdraw the appeal as the issues were resolved under the APA. The appeal was accordingly dismissed as withdrawn.

The Tribunal held that the assessee is a co-operative society engaged in providing credit facilities to its members and not a co-operative bank, thus Section 80P(4) is not attracted. It also held that the addition under Section 68 for cash deposits was unwarranted as the source was explained.

The Tribunal held that the assessee is a co-operative society engaged in providing credit facilities to its members and not a co-operative bank, thus Section 80P(4) is not attracted. It also held that the addition under Section 68 for cash deposits was unwarranted as the source was explained.

The Tribunal held that even though the assessee was not registered under Section 12A or Section 10(23C), it was assessed as an Association of Persons (AOP). In this status, the assessee is entitled to the benefits of carry forward and set-off of losses under Section 72 and depreciation under Section 32(1).

The Tribunal held that the assessee's grounds of appeal concerning the transfer pricing adjustment on overdue receivables (grounds 2 to 7) are allowed. The Tribunal found that the lower authorities erred in placing the burden on the assessee to prove the impact of working capital differences when the TPO had rejected the assessee's transfer pricing study and selected his own comparables. The Tribunal noted that the DRP appeared to have overlooked the commercial and economic significance of the issue and did not adjudicate on the assessee's objections on merits, relying instead on judicial precedents not directly relevant. It was undisputed that the overdue receivables arose from the international transactions and were closely linked to them. The Tribunal reasoned that determining the arm's length price without giving full effect to working capital adjustments was not in accordance with the Act and rules. Therefore, the Tribunal directed the AO to grant the assessee the working capital adjustment and, thereafter, determine the arm's length price. Once the working capital adjustment is granted, no further adjustment for interest on overdue receivables is required. The assessee was directed to furnish the computation for working capital adjustment if available. The miscellaneous grounds (8-11) were dismissed as consequential or premature, and ground 1 was general.

The Tribunal held that the assessee's claim falls under Section 80P(2)(a)(i) as its core activity involves providing credit facilities to members. Income earned from investing surplus funds, which is necessary to safeguard member deposits and meet withdrawal demands, is part of this core activity.

The Tribunal held that the AO erred in not considering the modified return filed in accordance with the UAPA. The assessment proceedings were pending when the modified return was filed, and the AO should have completed the assessment in line with the UAPA.

The Tribunal held that the cash deposits during demonetization were out of the opening balance and directed the deletion of the addition. The Tribunal also deleted the addition made by estimating business profit at 8% as the AO had not rejected the assessee's books of accounts.

The Tribunal restored the matters to the Assessing Officer, directing the assessee to surrender the old PAN and explain the cash deposit sources. The Tribunal found procedural irregularities and a lack of opportunity for the assessee to present its case.

The Tribunal condoned the delay in filing the appeal, finding the assessee's explanation to be reasonable. After reviewing the evidence presented, the Tribunal found the claimed agricultural income to be reasonable and not unsubstantiated.

The Tribunal held that Section 43CA, particularly sub-section (4) regarding non-cash payments, cannot be applied retrospectively to transactions entered into before its effective date. The valuation should be determined as of the agreement date.

The Tribunal restored the matters to the Assessing Officer, directing the assessee to surrender the old PAN and explain the cash deposit sources. The Tribunal found procedural irregularities and a lack of opportunity for the assessee to present its case.

The Tribunal restored the matters to the Assessing Officer, directing the assessee to surrender the old PAN and explain the cash deposit sources. The Tribunal found procedural irregularities and a lack of opportunity for the assessee to present its case.

The Tribunal allowed the appeal on grounds related to the disallowance of consumables and write-off of old advances. However, it dismissed grounds concerning the contribution to the Uttarakhand Relief Fund and general grounds.

The Tribunal restored the appeal to the Assessing Officer, noting that the assessee, an elderly individual with ailments, may not have received email notices. The assessee needs to substantiate the source of cash deposits with evidence.

The Tribunal held that the bank cannot be treated as an assessee in default because it was complying with binding interim court orders. These orders prevented TDS deduction, and statutory duties must yield to judicial mandates.

The Tribunal held that the assessee had indeed complied with the requirements of section 115BAB(7) by filing Form 10-ID for AY 2021-22 within the extended due date, which was accepted by the CPC. Therefore, the assessee is entitled to the concessional tax rate for AY 2023-24.

The Tribunal found that the assessee had filed substantial material before the CIT(A) which was not disputed. The ad hoc disallowances on purchases and expenses were considered unsustainable, and the ex parte dismissal by the CIT(A) was erroneous.

The Tribunal held that the CIT(A) ought to have condoned the delay, considering the bona fide reasons and numerous similar cases where delays were condoned. The Tribunal also ruled that the entire compensation received under the BSNL VRS, 2019 is exempt under Section 10(10B).

The Tribunal condoned the delay in filing the appeal before the CIT(A), finding sufficient cause as the assessment order was not served on the assessee's updated email address. The matter was remitted to the Assessing Officer for a fresh assessment on merits.