ITAT Bangalore Judgments — July 2026

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, respectfully following the decision of a coordinate bench in the assessee's own case for previous and subsequent assessment years, allowed grounds 3, 4, and 5. It directed the deletion of the transfer pricing adjustments amounting to Rs. 32,52,70,282/-. The Tribunal noted that the TPO had invented a hypothetical CUP method in previous years, similar to the present case, where the assessee's TNMM method was rejected. The Tribunal found the facts to be pari materia with those decided by the ITAT in earlier years. Regarding Ground No. 6, which concerned an opportunity to submit documentary evidence and show cause notices, the Tribunal held that the principle of audi alteram partem (right to be heard) was violated. Therefore, this ground was remanded to the AO for fresh adjudication after providing the assessee an opportunity to be heard. Ground No. 7 was consequential. The Tribunal noted that in previous years, consequent to the ITAT order, the TPO had allowed the assessee's claim for intra-group services expenses.

The Tribunal addressed several grounds. Regarding the transfer pricing adjustments, the Tribunal noted that the issue relatable to question No. 4 (impliedly concerning economic adjustments) was covered by High Court judgments in Thyssen Krupp Industries India (P.) Ltd. and Phoenix Mecvano (India) (P.) Ltd., which had attained finality up to the Supreme Court. Therefore, this aspect was dismissed. However, concerning ground No. 2.10 regarding working capital adjustment, the Tribunal found that the assessee had not adequately demonstrated material differences to warrant an adjustment. Consequently, the matter was remitted back to the AO/TPO for the assessee to demonstrate such differences. For the bad debts addition (ground No. 3), the Tribunal noted the assessee's contention of double taxation. As the DRP had rejected the objections on maintainability, the Tribunal deemed it fit to remand the matter back to the AO/TPO to examine the claim on merits. The Tribunal also directed the AO to restrict adjustments only to international transactions. The appeal was partly allowed for statistical purposes.

The Tribunal upheld the CIT(A)'s decision, following its own prior rulings in the assessee's own case for the previous assessment year. This pertained to the treatment of amortization of goodwill and adjustments for non-cenvatable customs duty.

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 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 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 held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal held that the ratio decidendi for Section 54F is equally applicable to Section 54, as both require reinvestment in a residential house. Since the assessee invested the entire capital gain in construction within the specified period, the deduction under Section 54 is allowable.

The Tribunal found that the assessee had provided sufficient explanation regarding his business operations and the source of funds, including affidavits and customer details. Therefore, the matter was remitted back to the AO for fresh adjudication.

The Tribunal condoned the delay in filing the appeals due to the medical condition of the trustees. It found that the assessee had submitted the required information, but it might not have been considered by the Assessing Officer before reporting non-compliance. Therefore, the matter was restored to the CIT(E) for reconsideration.

The Tribunal held that the notice issued under Section 148 of the Act was time-barred by 36 days. Consequently, the order passed under Section 148A(d) and the notice under Section 148 were quashed and set aside.

The Tribunal held that the appeals should not have been dismissed on technical grounds like limitation and maintainability, especially when similar delays were condoned for other employees. The Tribunal allowed the exemptions claimed under Section 10(10B) for retrenchment compensation and Section 10(10AA) for leave encashment.

The Tribunal held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal held that while the initial rejection was justified due to non-compliance with material laws, the assessee has since obtained the necessary fire safety and structural stability certificates. Therefore, the matter should be reconsidered by the CIT(E).

The Tribunal held that the rejection was based on hyper-technical grounds without granting an effective opportunity to rectify the defect. The matter was restored to the CIT(Exemptions) to consider the corrected application on merits.

The Tribunal allowed the appeals, following the judgment of the Hon'ble Supreme Court in the case of Totagars Co-operative Sales Society Ltd. vs. ITO, which held that interest income earned by a co-operative society from a co-operative bank is eligible for deduction under Section 80P(2)(d).

The Tribunal considered the assessee's argument that the interest income was earned from another co-operative society and that the deposits were made due to statutory obligations. The Tribunal noted that the Hon'ble Supreme Court's decision in Totagars Co-operative Sales Society Ltd. vs. ITO was distinguishable.

The Tribunal held that the AO failed to follow the specific directions given in the earlier order, which required verification of disclosure in the return. The AO's action of re-examining the genuineness of the loan instead of verifying the disclosure was found to be beyond the scope of the remand directions.

The Tribunal condoned the delay in filing the appeal due to the assessee's circumstances. It was held that the taxability of compensation received under the RFCTLARR Act, 2013, needed to be examined by the Assessing Officer.

The Tribunal held that while the initial rejection was justified due to non-compliance with material laws, the assessee has since obtained the necessary fire safety and structural stability certificates. Therefore, the matter should be reconsidered by the CIT(E).

The Tribunal considered the assessee's argument that the interest income was earned from another co-operative society and that the deposits were made due to statutory obligations. The Tribunal noted that the Hon'ble Supreme Court's decision in Totagars Co-operative Sales Society Ltd. vs. ITO was distinguishable.

The Tribunal held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal considered the assessee's argument that the interest income was earned from another co-operative society and that the deposits were made due to statutory obligations. The Tribunal noted that the Hon'ble Supreme Court's decision in Totagars Co-operative Sales Society Ltd. vs. ITO was distinguishable.

The Tribunal held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal held that the NFAC erred in dismissing the appeals on technical grounds like limitation and maintainability, especially when similar delays were condoned for other BSNL employees. The Tribunal allowed the exemptions claimed under Sections 10(10B) and 10(10AA) for retrenchment compensation and leave encashment, respectively.

The Tribunal accepted the assessee's request to withdraw the appeal. Therefore, the appeal was dismissed as withdrawn.

The Tribunal held that the rejection was based on hyper-technical grounds without granting an effective opportunity to rectify the defect. The matter was restored to the CIT(Exemptions) to consider the corrected application on merits.

The Tribunal considered the assessee's argument that the interest income was earned from another co-operative society and that the deposits were made due to statutory obligations. The Tribunal noted that the Hon'ble Supreme Court's decision in Totagars Co-operative Sales Society Ltd. vs. ITO was distinguishable.

The Tribunal considered the assessee's argument that the interest income was earned from another co-operative society and that the deposits were made due to statutory obligations. The Tribunal noted that the Hon'ble Supreme Court's decision in Totagars Co-operative Sales Society Ltd. vs. ITO was distinguishable.

The Tribunal condoned the 48-day delay in filing the appeal, finding that the reason provided constituted a 'sufficient cause' based on established legal principles emphasizing substantial justice over technicalities. The Tribunal also noted that the CIT(A)/NFAC dismissed the appeal without considering the merits and without providing a proper opportunity for hearing, violating principles of natural justice.

The Tribunal held that the CIT(E) cannot deem an earlier registration invalid without following the cancellation procedure under Section 12AB(4). A registration, once granted and not cancelled, remains valid. Therefore, the CIT(E)'s order was quashed.

The Tribunal condoned the delay in filing the appeals due to the trustees' medical unfitness. It found that the assessee had submitted information before the Assessing Officer, but this might not have been considered before the CIT(E) passed the order.

The Tribunal condoned the delay in filing the appeal and restored the matter to the Assessing Officer for de novo adjudication. The assessee was directed to provide all supporting details and cooperate with the proceedings.

The Tribunal held that Section 69A cannot be invoked merely due to a discrepancy between VAT turnover and bank deposits; it requires tangible material linking the amount to an unexplained source. The Tribunal directed that the profit element embedded in the suppressed sales should be taxed, not the entire deposit.

The Tribunal held that the show cause notice issued under Section 148A(b) was illegal and bad in law due to the violation of the mandatory minimum notice period. Consequently, the assessment order and the penalty order were quashed.

The Tribunal set aside the CIT(A)'s order and remitted the issue back for de novo consideration. The assessee was granted an opportunity to appear before the CIT(A) and canvas all grounds.

The Tribunal held that the success fee paid to the advisor was incurred wholly and exclusively in connection with the sale of shares by the assessee. Therefore, it was allowable as a deduction in computing capital gains.

The Tribunal admitted additional evidence from the assessee and found it necessary to re-examine the issue. The Tribunal set aside the CIT(A)'s order and restored the matter to the AO for fresh adjudication.

The Tribunal found a factual dispute regarding the service of notices and the assessee's compliance. It noted that the CIT(A) had not effectively examined the material filed by the assessee.

The Tribunal held that the reassessment proceedings were initiated without jurisdiction as the notice under Section 148 was issued after the commencement of the new regime and was barred by limitation as per Supreme Court decisions.

The Tribunal acknowledged that both the AO's and CIT(A)'s orders were ex-parte and had not considered the merits of the case. The assessee claimed they missed notices sent via the portal.