ITAT Bangalore Judgments — July 2026

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 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 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 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 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 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 held that each application for registration must be considered independently and the previous rejection does not operate as res judicata. The CIT(E) failed to apply independent mind to the fresh application and the rejection was mechanical.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the issue was clearly covered in favour of the assessee. It noted that for Assessment Years 2015-16 and 2021-22, the Hon'ble Karnataka High Court, in its orders dated 8 October 2025, confirmed the coordinate benches' decisions that the impugned income was not chargeable to tax in India. The Tribunal also noted the Revenue's categorical acceptance that the issue was squarely covered by the Hon'ble Supreme Court's decision in Engineering Analysis Centre of Excellence Private Limited v. Commissioner of Income Tax and another. Respectfully following the Hon'ble Karnataka High Court's decision, the Tribunal held that the sum of ₹53,34,48,706 received by the assessee from the sale of software is not chargeable to tax in India. Consequently, the order of the Assessing Officer was reversed, and grounds 2 to 4 of the appeal were allowed. Ground 1 was general and dismissed. Ground 5, relating to penalty proceedings, was premature and dismissed. The ratio decidendi is that prior High Court and Supreme Court decisions on identical facts and issues are binding on the Tribunal.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal restored both applications to the CIT(E) for fresh adjudication. The assessee was granted another opportunity to furnish all required details and receive a reasonable hearing.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the rejection of the application due to a mistaken belief about a wrong code was not justified. The assessee should have been given an opportunity to correct the application.

The Tribunal admitted additional evidence for a portion of the disallowed expenses (Rs. 37,48,685) and restored it to the AO for de novo adjudication. For the remaining disallowed amount (Rs. 1,20,56,670), the Tribunal found merit in the assessee's contentions and directed its deletion.

The Tribunal held that for an 'other person' under Section 153C, the deemed date of initiation of search, based on the receipt of seized material and recording of satisfaction, governs the applicability of Section 153C(3). Since this deemed date fell after the cut-off date of April 1, 2021, the proceedings under Section 153C were without jurisdiction.

The Tribunal held that for an 'other person' under Section 153C, the deemed date of initiation of search, based on the receipt of seized material and recording of satisfaction, governs the applicability of Section 153C(3). Since this deemed date fell after the cut-off date of April 1, 2021, the proceedings under Section 153C were without jurisdiction.

The Tribunal held that each application for registration must be considered independently and the previous rejection does not operate as res judicata. The CIT(E) failed to apply independent mind to the fresh application and the rejection was mechanical.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal condoned the delay in filing the appeal due to a bona fide misunderstanding of the remedy. It found that the assessee had reasonable cause for non-compliance during the COVID-19 period and deserved another opportunity to furnish the required details.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that for an 'other person' under Section 153C, the deemed date of initiation of search, based on the receipt of seized material and recording of satisfaction, governs the applicability of Section 153C(3). Since this deemed date fell after the cut-off date of April 1, 2021, the proceedings under Section 153C were without jurisdiction.

The Tribunal held that for an 'other person' under Section 153C, the deemed date of initiation of search, based on the receipt of seized material and recording of satisfaction, governs the applicability of Section 153C(3). Since this deemed date fell after the cut-off date of April 1, 2021, the proceedings under Section 153C were without jurisdiction.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that the NFAC's dismissal on technical grounds like limitation and maintainability was incorrect. It allowed the appeals, granting the assessees the benefit of exemption for retrenchment compensation under Section 10(10B) and full leave encashment under Section 10(10AA) of the Income Tax Act.

The Tribunal held that for an 'other person' under Section 153C, the deemed date of initiation of search, based on the receipt of seized material and recording of satisfaction, governs the applicability of Section 153C(3). Since this deemed date fell after the cut-off date of April 1, 2021, the proceedings under Section 153C were without jurisdiction.

The Tribunal held that for an 'other person' under Section 153C, the deemed date of initiation of search, based on the receipt of seized material and recording of satisfaction, governs the applicability of Section 153C(3). Since this deemed date fell after the cut-off date of April 1, 2021, the proceedings under Section 153C were without jurisdiction.

The Tribunal held that for an 'other person' under Section 153C, the deemed date of initiation of search, based on the receipt of seized material and recording of satisfaction, governs the applicability of Section 153C(3). Since this deemed date fell after the cut-off date of April 1, 2021, the proceedings under Section 153C were without jurisdiction.

The Tribunal restored both applications to the CIT(E) for fresh adjudication. The assessee was granted another opportunity to furnish all required details and receive a reasonable hearing.

The Tribunal held that interest earned by a cooperative society from temporary parking of surplus funds with banks is attributable to its business of providing credit facilities and is eligible for deduction under Section 80P(2)(a)(i). The Tribunal followed the jurisdictional High Court's decision in Tumkur Merchants Souharda Credit Cooperative Ltd.

The Tribunal noted that the assessee is a credit cooperative society providing financial facilities to its members. The issue revolves around whether interest on statutory deposits is eligible for deduction under Section 80P(2)(a)(i). The judgment seems to be in progress as the provided text cuts off.

The Tribunal held that only real net winnings from online gaming are taxable, not gross wallet credits or intermediate winnings. Since the assessee incurred a net loss after considering buy-in amounts, the addition was unsustainable.

The Tribunal held that the entire amount of ₹42,80,545/- represented maturity proceeds of NSCs. Only the interest component of ₹11,07,145/- was liable to be taxed as income from other sources.

The Tribunal held that the PCIT's order under Section 263 was not sustainable. The assessment order was not erroneous or prejudicial to the revenue as the assessee had provided plausible explanations and supporting documents, and the PCIT failed to demonstrate actual loss of revenue.

The Tribunal held that the dividend and interest income earned from banks, which were invested as per statutory requirements or to maintain liquidity, are eligible for deduction under Section 80P(2)(a)(i). The Tribunal followed its own prior decision on similar facts.

The Tribunal found that the lower authorities did not properly appreciate the assessee's activities or adequately explain why the Section 80P deduction was not allowable. For AY 2020-21, the appeal was restored to the Assessing Officer for fresh examination.

The Tribunal condoned the delay of 639 days, citing sufficient cause and prioritizing substantial justice over technicalities. The Tribunal directed the deletion of an addition of Rs. 1,06,25,000/- on account of unsecured loans from Smt. Susheelamma, finding that the AO had accepted similar loans and the assessee had provided sufficient evidence. The Tribunal also directed the deletion of an addition of Rs. 77,32,120/- towards cash deposits, attributing part to agricultural income and the balance to unsecured loans/advances from customers, to avoid double addition.

The Tribunal admitted the assessee's bank statement as additional evidence and restored the issue to the Assessing Officer for de novo adjudication. The addition was set aside for detailed verification of the bank transactions.