ITAT Bangalore Judgments — July 2026

The Tribunal held that the assessee had a reasonable cause for the belated filing of the audit report due to the negligence of the previous auditor. Since the audit report was submitted before the assessment was finalized and there was no wilful default or loss to the exchequer, the penalty was not leviable.

The Tribunal found that the CIT(A) incorrectly calculated the delay and failed to consider the assessee's submission regarding the date of service of the assessment order. Consequently, the matter was remitted back to the CIT(A) for fresh adjudication on merits.

The Tribunal found that the CIT(E) erred by not considering the assessee's submitted replies and documents. The assessee's activities were charitable, funded by government agencies and banks, and not commercial in nature.

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 found that the CIT(E) erred by not considering the assessee's submitted replies and documents. The assessee's activities were charitable, funded by government agencies and banks, and not commercial in nature.

The Tribunal held that the addition sustained by the CIT(A) regarding the purchase of immovable property was to be deleted, as the assessee had provided sufficient evidence of personal savings. The Tribunal also allowed the HRA exemption claim, finding it to be in accordance with the relevant provisions.

The Tribunal held that the notice under Section 148 was issued beyond the limitation period as per Section 149 read with its first proviso. Consequently, the entire reassessment proceedings were quashed.

The Tribunal held that interest income earned from deposits of surplus funds, even if made with a cooperative bank, is not eligible for deduction under Section 80P(2)(a)(i) as it does not directly arise from the business of providing credit facilities to members. The Tribunal relied on the jurisdictional High Court's decision in the Tumkur Merchants case.

The Tribunal held that the assessee's argument for excluding Sutherland Global Services Pvt. Ltd., Tech Mahindra Business Services Ltd., and TTEC India Customer Solutions Pvt. Ltd. based on the turnover filter is valid. The Tribunal noted that the assessee's revenue was Rs. 79,27,51,333/-, while Sutherland Global Services Pvt. Ltd. had a revenue of Rs. 1944.87 crores, Tech Mahindra Business Services Ltd. had Rs. 8892 crores, and TTEC India Customer Solutions Pvt. Ltd. had Rs. 418.33 crores. The Tribunal referred to a coordinate bench decision in *Marvell India Pvt. Ltd. vs. DCIT*, which accepted high turnover as a ground for excluding companies from the comparable list when dealing with companies of significantly different turnovers. The Tribunal found that the three mentioned companies had revenues more than 10 times that of the assessee, making them inappropriate comparables. Therefore, the Tribunal directed the Assessing Officer to exclude these three companies and compute the ALP accordingly. The Tribunal also noted that the assessee had not pressed other grounds raised in the appeal.

The Tribunal restored the matter to the Assessing Officer for de novo adjudication, granting the assessee another opportunity to present its case and submit supporting documents. The assessee was directed to cooperate fully with the assessment proceedings.

The Tribunal admitted additional evidence, including a civil suit, showing the assessee might be a benamidar. The issue was restored to the AO for fresh adjudication, allowing the assessee to raise all grounds, including the validity of reassessment.

The Tribunal found no merit in the AO's ad hoc estimation of commission at 8% without independent evidence. The Tribunal restored the issue of commission income and the deduction under Chapter VI-A to the AO for de novo adjudication, granting the assessee one more opportunity to furnish necessary documents.

The Tribunal condoned the delay in filing the appeal due to sufficient cause. The Tribunal found that the material on record did not clearly establish whether the deduction was claimed under section 80P(2)(a)(i) or 80P(2)(d). Therefore, the matter was restored to the Assessing Officer for fresh examination.

The Tribunal held that TDS credit can only be claimed by the entity that has offered the corresponding income to tax. Therefore, the individual assessee was not entitled to the TDS credit. However, the Tribunal directed the assessee to file an application in the name of the partnership firm for claiming the credit.

The Tribunal found that the assessee had reasonable cause for the delay in filing the appeal before the CIT(A) due to issues with obtaining Form 16. The delay was condoned, and the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal held that under Section 15 of the Income Tax Act, salary due is taxable, not just salary received. Since both the assessee's claim of non-receipt and the employer's reporting of salary due required verification, the matter was restored to the Assessing Officer.

The Tribunal held that the penalty notice and order were invalid because they failed to specify under which limb of Section 270A the alleged misreporting and underreporting of income occurred. Relying on various High Court and Tribunal decisions, the Tribunal set aside the penalty.

The Tribunal held that the delay in filing appeals before the CIT(A) was due to the assessee's unawareness of the orders following the death of his tax consultant and his medical condition. Therefore, the delay was condoned.

The Tribunal found the assessee's reasons for non-appearance before the lower authorities unsatisfactory and imposed a cost. However, the appeals were restored to the Assessing Officer for a fresh decision on merits after giving the assessee an opportunity to be heard.

The Tribunal found the assessee's reasons for non-appearance before the lower authorities unsatisfactory and imposed a cost. However, the appeals were restored to the Assessing Officer for a fresh decision on merits after giving the assessee an opportunity to be heard.

The Tribunal condoned the delay in filing the appeal, citing bonafide reasons. It also admitted the additional ground of appeal, holding that the notice issued under Section 148 was barred by limitation and invalid, consequently quashing the reassessment order.

The Tribunal held that the additions were not justified as the assessee explained the cash deposits were made from earlier cash withdrawals from the same bank account. It also held that withdrawal from one's own bank account is not unexplained expenditure.

The Tribunal held that the delay was supported by sufficient cause, as the assessee was pursuing an alternative remedy which remained unattended. The Tribunal reversed the CIT(A)'s order refusing condonation of delay and restored the matter to the CIT(A) for adjudication on merits.

The Tribunal held that the notice issued under section 148A(b) was invalid because it granted the assessee less than the mandatory seven days to respond. Consequently, the consequential assessment order was quashed.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to sufficient cause shown by the assessee. The matter was restored to the CIT(A) for adjudication on merits, as the original appeal was dismissed without considering the substantive issues.

The Tribunal held that the commission disallowance was ad hoc and unsupported by evidence, and the interest disallowance was unsustainable as the payee was not a related party and the interest rate was reasonable. Both disallowances were directed to be deleted.

The Tribunal held that the delay in filing appeals before the CIT(A) was due to the assessee's unawareness of the orders following the death of his tax consultant and his medical condition. Therefore, the delay was condoned.

The Tribunal held that TDS credit can only be claimed by the entity that has offered the corresponding income to tax. Therefore, the individual assessee was not entitled to the TDS credit. However, the Tribunal directed the assessee to file an application in the name of the partnership firm for claiming the credit.

The Tribunal found the assessee's reasons for non-appearance before the lower authorities unsatisfactory and imposed a cost. However, the appeals were restored to the Assessing Officer for a fresh decision on merits after giving the assessee an opportunity to be heard.

The Tribunal found the assessee's reasons for non-appearance before the lower authorities unsatisfactory and imposed a cost. However, the appeals were restored to the Assessing Officer for a fresh decision on merits after giving the assessee an opportunity to be heard.

The Tribunal found the assessee's reasons for non-appearance before the lower authorities unsatisfactory and imposed a cost. However, the appeals were restored to the Assessing Officer for a fresh decision on merits after giving the assessee an opportunity to be heard.

The Tribunal found the assessee's reasons for non-appearance before the lower authorities unsatisfactory and imposed a cost. However, the appeals were restored to the Assessing Officer for a fresh decision on merits after giving the assessee an opportunity to be heard.

The Tribunal restored the matter to the Assessing Officer for de novo adjudication, granting the assessee another opportunity to present its case and submit supporting documents. The assessee was directed to cooperate fully with the assessment proceedings.

The Tribunal restored the matter to the Assessing Officer for de novo adjudication, granting the assessee another opportunity to present its case and submit supporting documents. The assessee was directed to cooperate fully with the assessment proceedings.

The Tribunal restored the matter to the Assessing Officer for de novo adjudication, granting the assessee another opportunity to present its case and submit supporting documents. The assessee was directed to cooperate fully with the assessment proceedings.

The Tribunal held that the assessee's ignorance of the online appeal filing procedure constituted a sufficient cause for the delay. The claim for foreign tax credit should have been examined on merits, as the assessee had filed Form No. 67 before the due date for filing the return.

The Tribunal held that the assessee is eligible for deduction under Section 10(23C)(iiiad) as the receipts of each individual institution did not exceed the threshold limit of Rs. 1 crore. This decision followed the jurisdictional High Court's ruling on a similar matter.

The Tribunal, in the interest of justice, granted one final opportunity to the assessee before the AO to submit documentary evidence for claiming deduction under Section 54. The assessee was cautioned to cooperate fully.

The Tribunal held that the delay was due to reasons beyond the assessee's control and was sufficiently explained. Therefore, the disallowance under Section 36(1)(va) was not sustainable.

The Tribunal found that the assessee had filed a delay condonation application and evidence of its upload. It also noted the assessee's claim of not receiving hearing notices. Therefore, the Tribunal remitted the issue to the CIT(A) for fresh consideration on merits.

The Tribunal allowed grounds related to the DAPE issue, following its own prior ruling where the transfer pricing analysis accepted the Indian entity's pricing. The interest income issue was set aside and remitted to the AO for fresh consideration.

The Tribunal considered the assessee's request for withdrawal and the lack of objection from the revenue. Consequently, the Tribunal dismissed the appeals.

The Tribunal considered the assessee's request for withdrawal and the lack of objection from the revenue. Consequently, the Tribunal dismissed the appeals.

The Tribunal held that the filing of the audit report in Form 10B is directory and not mandatory. Following the principle of consistency and a coordinate bench decision, the Tribunal directed the AO to allow the exemption claim.

The Tribunal held that additions based solely on third-party statements and uncorroborated entries in an excel sheet, without independent corroborative evidence or an opportunity for cross-examination, cannot be sustained. The Tribunal followed numerous judicial precedents on identical facts.

The Tribunal held that the marketing and advertisement expenditure was revenue in nature, incurred for promoting an existing business. It also held that payments for subscription-based software and cloud services to non-residents did not constitute royalty, thus not requiring TDS deduction.

The Tribunal held that additions based solely on third-party statements and uncorroborated entries in an excel sheet, without independent corroborative evidence or an opportunity for cross-examination, cannot be sustained. The Tribunal followed numerous judicial precedents on identical facts.

The Tribunal held that additions based solely on third-party statements and uncorroborated entries in an excel sheet, without independent corroborative evidence or an opportunity for cross-examination, cannot be sustained. The Tribunal followed numerous judicial precedents on identical facts.

The Tribunal held that additions based solely on third-party statements and uncorroborated entries in an excel sheet, without independent corroborative evidence or an opportunity for cross-examination, cannot be sustained. The Tribunal followed numerous judicial precedents on identical facts.

The Tribunal held that additions based solely on third-party statements and uncorroborated entries in an excel sheet, without independent corroborative evidence or an opportunity for cross-examination, cannot be sustained. The Tribunal followed numerous judicial precedents on identical facts.