ITAT Bangalore Judgments — August 2026

The Tribunal considered the assessee's application for withdrawal dated 26.08.2026. As the assessee did not wish to press the grounds of appeal and sought to withdraw the appeal, and the Revenue had no objection, the Tribunal permitted the assessee to withdraw the appeal. Consequently, the appeal was dismissed as withdrawn. The operative direction was to dismiss the appeal. No specific issue was left undecided; the entire appeal was disposed of based on the assessee's request for withdrawal.

The Tribunal held that the interest expenditure was incurred for the purposes of the assessee's business. It was also noted that sufficient interest-free funds were available to cover the investments, supporting the allowability of the interest.

The Tribunal held that the Assessing Officer should have granted the assessee an opportunity to be heard before rejecting the immunity application. The matter was restored to the Assessing Officer to decide the immunity application afresh, considering the conditions for immunity and the delay in filing Form 68.

The Tribunal held that rejecting the application without granting an adjournment violated the principles of natural justice. Therefore, the matter was remitted back to the CIT (Exemptions) for a fresh decision.

The Tribunal admitted additional evidence and restored the appeals to the Assessing Officer for fresh adjudication. The AO is directed to verify the TDS compliance, identity, creditworthiness, and genuineness of unsecured loan transactions.

The Tribunal condoned the delay in filing the appeals, citing the assessee's age, health, and circumstances as sufficient cause. It also held that unabated assessments could not be disturbed under Section 153C without specific incriminating material for those years.

The Tribunal dismissed the appeal on grounds related to professional fees, weighted deduction for R&D, violation of natural justice, and non-admission of additional evidence. However, it allowed the appeal on grounds related to depreciation and export rebate receivables, remanding these issues for re-computation.

The Tribunal held that retrenchment compensation from BSNL is exempt under Section 10(10B) and accumulated leave encashment is eligible for exemption under Section 10(10AA) with the revised limit applied retrospectively. The Assessing Officer is directed to allow these exemptions.

The Tribunal addressed the issues as follows: Regarding the validity of the assessment order and DRP directions, the judgment does not explicitly record findings on the grounds related to limitation or the invalidity of DRP directions due to manual DIN quoting. However, the appeal is partly allowed, implying these grounds might not have been the sole basis for the decision. Concerning the transfer pricing adjustment for manufacturing activity, the Tribunal directed the exclusion of specific comparables (Amway India Enterprise Private Ltd., Avenue Food Plaza Private Limited, Euro India Fresh Foods Ltd, Haldiram Bhujiwala Ltd., and MTR Foods Private Ltd.) while upholding the inclusion of GITS Foods Products Private Ltd. This resulted in the grounds related to manufacturing activity being partly allowed. For the AMP expenses, the Tribunal held that the Bright Line Test, adopted by the TPO, lacks statutory mandate as per the Delhi High Court ruling in Sony Ericson Mobile Communications (India) Pvt. Ltd. vs. CIT. Furthermore, the Tribunal found no material on record to prove any arrangement between the assessee and its associated enterprises for incurring AMP expenses on their behalf. Consequently, the transfer pricing adjustment on account of AMP expenses was deleted, and the grounds related to this issue were allowed. Grounds pertaining to the initiation of penalty proceedings were dismissed as premature.

The Tribunal held that FCCDs, which are convertible into equity shares at a future date, cannot be equated with the issue of equity shares for the purpose of Section 56(2)(viib) of the Act. Therefore, the consideration received against such FCCDs is outside the scope of this section.

The Tribunal held that the reassessment proceedings were not sustainable in law because the Assessing Officer did not dispose of the assessee's objections by passing a speaking order, as mandated by judicial precedents.

The Tribunal dismissed the appeal against the Section 263 revision order. However, the appeal against the subsequent assessment order was allowed for statistical purposes, remanding the matter for fresh assessment.

The Tribunal admitted additional evidence and restored the appeals to the Assessing Officer for fresh adjudication. The AO is directed to verify the TDS compliance, identity, creditworthiness, and genuineness of unsecured loan transactions.

The Tribunal held that an assessee registered under the Karnataka Souharda Sahakari Act, 1997, is to be treated as a co-operative society for the purpose of Section 80P. It also found that the principle of mutuality was not lost as the assessee dealt only with its members.

The Tribunal restored the issues of unsecured loans and estimated profit to the Assessing Officer for fresh adjudication. The assessee needs to establish the identity, creditworthiness of the creditor, and genuineness of the ₹1 crore credit, and provide quantitative details for the profit estimation.

The Tribunal condoned the delay in filing the appeals, citing the assessee's age, health, and circumstances as sufficient cause. It also held that unabated assessments could not be disturbed under Section 153C without specific incriminating material for those years.

The Tribunal held that retrenchment compensation from BSNL is exempt under Section 10(10B) and accumulated leave encashment is eligible for exemption under Section 10(10AA) with the revised limit applied retrospectively. The Assessing Officer is directed to allow these exemptions.

The Tribunal held that the reassessment proceedings were not sustainable in law because the Assessing Officer did not dispose of the assessee's objections by passing a speaking order, as mandated by judicial precedents.

The Tribunal held that the ex-gratia compensation received under the BSNL VRS, 2019 is eligible for exemption under Section 10(10B) of the Act, following various coordinate bench decisions. The Assessing Officer was directed to allow the exemption.

The Tribunal condoned the delay in filing the appeals, citing the assessee's age, health, and circumstances as sufficient cause. It also held that unabated assessments could not be disturbed under Section 153C without specific incriminating material for those years.

The Tribunal held that the revisionary order passed by the CIT was barred by limitation. Furthermore, the Tribunal found that the assessment order was not erroneous as the AO had made necessary inquiries and taken a plausible view, supported by judicial precedents.

The Tribunal set aside the CIT(A)'s ex-parte order and restored the matter for de novo adjudication. The assessee is granted one more opportunity to present its case on merits before the CIT(A).

The Tribunal condoned the delay in filing the appeals, citing the assessee's age, health, and circumstances as sufficient cause. It also held that unabated assessments could not be disturbed under Section 153C without specific incriminating material for those years.

The Tribunal condoned the delay in filing the appeals, citing the assessee's age, health, and circumstances as sufficient cause. It also held that unabated assessments could not be disturbed under Section 153C without specific incriminating material for those years.

The Tribunal found that the CIT(A) did not properly examine the details submitted by the assessee and that an 8% net profit rate for bullion trading seemed unusually high. The Tribunal restored the issue to the Assessing Officer for fresh adjudication.

The Tribunal dismissed the appeal against the Section 263 revision order. However, the appeal against the subsequent assessment order was allowed for statistical purposes, remanding the matter for fresh assessment.

The Tribunal held that the ex-gratia compensation received under the BSNL VRS, 2019 is eligible for exemption under Section 10(10B) of the Act, following various coordinate bench decisions. The Assessing Officer was directed to allow the exemption.

The Tribunal condoned the delay in filing the appeals, citing the assessee's age, health, and circumstances as sufficient cause. It also held that unabated assessments could not be disturbed under Section 153C without specific incriminating material for those years.

The Tribunal condoned the delay in filing the appeal, finding sufficient cause. It restored two grounds relating to disallowances to the Assessing Officer for verification of whether the assessee had already made suo motu disallowances.

The Tribunal condoned the delay in filing the appeals, citing the assessee's age, health, and circumstances as sufficient cause. It also held that unabated assessments could not be disturbed under Section 153C without specific incriminating material for those years.

The Tribunal addressed several grounds. Regarding the inclusion of Microland Limited as a comparable for IT-enabled Services (ITeS), the Tribunal found that Microland has a separate reportable segment for IT-enabled Services, distinct from its infrastructure management services. Therefore, it directed the AO/TPO to consider the IT-enabled Services segment of Microland Limited for benchmarking the international transaction of 'Provision of ITeS'. This led to Grounds No. 14-20 being partly allowed. For the Distribution Segment, the Tribunal found that the eligibility for the 3% tolerance band required factual verification. It restored this issue to the AO/TPO to examine the assessee's eligibility based on the proviso to section 92C and the Notification dated 28.06.2022. If the variation is within 3%, the adjustment should be deleted. Accordingly, Grounds No. 21-23 were allowed for statistical purposes. Grounds pertaining to outstanding trade receivables (No. 24-29) were not pressed by the assessee and were dismissed. The ground regarding penalty proceedings (No. 30) was dismissed as premature. The judgment does not explicitly address grounds related to limitation, the AO failing to give effect to DRP directions, or the overall quantum of adjustment for IT services and ITeS beyond the specific issue of Microland, nor does it detail the reasoning for the other grounds.

The Tribunal held that the CIT(A) ought to have condoned the delays and entertained the appeals on merits, as similar claims by BSNL employees had been allowed by various benches. The judgment of the Supreme Court in Goetze (India) Ltd. was deemed not applicable to appellate authorities.

The Tribunal restored the matter to the Assessing Officer, directing the assessee to provide evidence for the cash deposits. The penalty proceedings were also set aside and restored to the Assessing Officer.

The Tribunal restored the matter to the Assessing Officer, directing the assessee to provide evidence for the cash deposits. The penalty proceedings were also set aside and restored to the Assessing Officer.

The Tribunal restored the matter to the Assessing Officer, directing the assessee to provide evidence for the cash deposits. The penalty proceedings were also set aside and restored to the Assessing Officer.

The Tribunal held that the CIT(A) ought to have condoned the delays and entertained the appeals on merits, as similar claims by BSNL employees had been allowed by various benches. The judgment of the Supreme Court in Goetze (India) Ltd. was deemed not applicable to appellate authorities.

The Tribunal condoned the delay, finding merit in the assessee's explanation regarding incorrect email communication. It was held that the AO's estimation of income was incorrect as no defects were pointed out in the audited books of accounts and the nature of the business does not guarantee uniform profits.

The Tribunal held that since the assessee maintained audited books of accounts and had a history of regular filings, the arbitrary estimation of profit by the lower authorities was not justified. The book results declared by the assessee could not be ignored without evidence to the contrary.

The Tribunal held that the notice issued under Section 148 was barred by limitation as it was issued after the expiry of the six-year period from the end of the assessment year. Consequently, all subsequent proceedings were deemed unsustainable.

The Tribunal restored the matter to the Assessing Officer, directing the assessee to provide evidence for the cash deposits. The penalty proceedings were also set aside and restored to the Assessing Officer.

The Tribunal condoned the delay in filing the appeal before the CIT(A) by excluding the period of Supreme Court-extended limitation due to COVID-19. The Tribunal set aside the lower authorities' orders and remitted the issue to the AO for fresh consideration.

The Tribunal held that the assessee had received the sale consideration on the date of the sale agreement and had invested it in new agricultural land the next day. Therefore, the condition of investing within two years of sale was satisfied, entitling the assessee to the deduction.

The Tribunal held that the APMC sale bills, issued by a government-controlled market committee, coupled with land ownership records, sufficiently supported the claim of agricultural income. The absence of detailed expense records or specific crop mentions in land records was not sufficient to reject the claim, especially for small-scale agricultural activities.

The Tribunal condoned the delay in filing the application, considering the assessee's charitable nature and the CBDT circular extending the due date. The matter was remitted to the CIT(E) for reconsideration on merits.

The Tribunal held that the CIT(A) ought to have condoned the delays and entertained the appeals on merits, as similar claims by BSNL employees had been allowed by various benches. The judgment of the Supreme Court in Goetze (India) Ltd. was deemed not applicable to appellate authorities.

The Tribunal noted that the assessee had submitted VAT and GST returns disclosing sales, and the documents submitted supported the assessee's contention of cash sales. However, these documents were not verified by the lower authorities.

The Tribunal condoned the delay in filing the appeal due to a bona fide mistake. On merits, the Tribunal noted that the Assessing Officer adopted stamp duty values without awaiting a valuation report and that the assessee's claim was based on a registered valuer's report.

The Tribunal held that the CIT(A) ought to have condoned the delays and entertained the appeals on merits, as similar claims by BSNL employees had been allowed by various benches. The judgment of the Supreme Court in Goetze (India) Ltd. was deemed not applicable to appellate authorities.

The Tribunal restored the matter to the Assessing Officer, directing the assessee to provide evidence for the cash deposits. The penalty proceedings were also set aside and restored to the Assessing Officer.

The Tribunal held that the CIT(A) ought to have condoned the delays and entertained the appeals on merits, as similar claims by BSNL employees had been allowed by various benches. The judgment of the Supreme Court in Goetze (India) Ltd. was deemed not applicable to appellate authorities.