ITAT Chandigarh Judgments — February 2026

The Tribunal observed that the assessee provided additional documents, including bank statements and pictures, indicating charitable activities undertaken after the initial rejection date. Recognizing that these documents could have a material bearing on the registration applications, the Tribunal set aside the impugned orders and remanded the matter back to the CIT(E) for a de novo consideration and adjudication, directing the assessee to present its case.

The Tribunal upheld its previous ruling, stating that an unsigned agreement, not acted upon or signed by the assessee, cannot be considered "incriminating material." The AO failed to provide other evidence to support a higher fair rental value for the property. Therefore, the addition made based solely on such a document was deemed invalid and ordered to be deleted.

The Income Tax Appellate Tribunal (ITAT) noted that the assessee was a 50% partner in M/s Anant Stones Crusher, which had disclosed Rs.62.87 Lacs as estimated unaccounted profit for AYs 2018-19 & 2019-20. The Tribunal held that telescoping benefit should be granted, as unaccounted cash accumulates over time, and the assessee, being a substantial partner, is entitled to it. Consequently, the addition of Rs.5.50 Lacs made by the AO under Section 69A was deleted.

The Tribunal condoned the 1290-day delay in filing the appeal due to the assessee's financial hardship. On merits, the quantum addition was restricted to Rs. 2 Lakhs, deleting the balance amount. Consequently, the penalty levied under Section 271(1)(c) was deleted given the significant relief provided in the quantum addition.

The Tribunal upheld its previous ruling, stating that an unsigned agreement, not acted upon or signed by the assessee, cannot be considered "incriminating material." The AO failed to provide other evidence to support a higher fair rental value for the property. Therefore, the addition made based solely on such a document was deemed invalid and ordered to be deleted.

The Tribunal upheld its previous ruling, stating that an unsigned agreement, not acted upon or signed by the assessee, cannot be considered "incriminating material." The AO failed to provide other evidence to support a higher fair rental value for the property. Therefore, the addition made based solely on such a document was deemed invalid and ordered to be deleted.

The Tribunal observed that the assessee provided additional documents, including bank statements and pictures, indicating charitable activities undertaken after the initial rejection date. Recognizing that these documents could have a material bearing on the registration applications, the Tribunal set aside the impugned orders and remanded the matter back to the CIT(E) for a de novo consideration and adjudication, directing the assessee to present its case.

The Tribunal found that the CIT(E) erred in its finding, noting that the trust also engaged in significant charitable activities such as education, medical aid, yoga, and organizing eye camps. It highlighted that the trust had previously been granted registration under Section 12A for its charitable objectives. Consequently, the Tribunal directed the CIT(E) to grant registration under Section 80G(5)(iii) to the assessee trust.

The Tribunal set aside the ex-parte orders of both the AO and CIT(A). It directed the AO to implead all legal heirs and re-examine the taxability of the land sale, specifically whether the agricultural land constituted a "capital asset" under the Income Tax Act, and to verify the reinvestment claim.