ITAT Chandigarh Judgments — April 2026

The Tribunal noted that the assessee failed to provide compliance before both the AO and CIT(A) despite multiple opportunities. However, considering the request for another opportunity, the Tribunal set aside the matter to the CIT(A) with a cost of Rs. 5,000/- to be deposited by the assessee. The assessee was directed to make proper compliance before the CIT(A).

The Tribunal held that the issue of conversion charges and interest is a mixed question of law and fact, requiring factual investigation, and thus additional grounds were not admitted. However, penalties under Section 271(1)(c) were deleted as the issue was debatable and consistent with prior years' decisions.

The Tribunal held that the issue of conversion charges and interest is a mixed question of law and fact, requiring factual investigation, and thus additional grounds were not admitted. However, penalties under Section 271(1)(c) were deleted as the issue was debatable and consistent with prior years' decisions.

The Tribunal held that the issue of conversion charges and interest is a mixed question of law and fact, requiring factual investigation, and thus additional grounds were not admitted. However, penalties under Section 271(1)(c) were deleted as the issue was debatable and consistent with prior years' decisions.

The Tribunal held that the issue of conversion charges and interest is a mixed question of law and fact, requiring factual investigation, and thus additional grounds were not admitted. However, penalties under Section 271(1)(c) were deleted as the issue was debatable and consistent with prior years' decisions.

The Tribunal held that the issue of conversion charges and interest is a mixed question of law and fact, requiring factual investigation, and thus additional grounds were not admitted. However, penalties under Section 271(1)(c) were deleted as the issue was debatable and consistent with prior years' decisions.

The Tribunal held that the issue of conversion charges and interest is a mixed question of law and fact, requiring factual investigation, and thus additional grounds were not admitted. However, penalties under Section 271(1)(c) were deleted as the issue was debatable and consistent with prior years' decisions.

The Tribunal found that the assessee did not comply with notices uploaded on the ITBA portal and that the department failed to provide evidence of service. Consequently, the matter was remanded back to the Assessing Officer for de novo assessment and adjudication.

The Tribunal held that interest earned on ADB loans parked in FDRs is not revenue in nature and therefore not taxable. However, the addition of prior period expenses was remitted back to the AO for re-examination due to incomplete facts presented to the revenue authorities.

The Tribunal found that the assessee did not comply with notices uploaded on the ITBA portal and that the department failed to provide evidence of service. Consequently, the matter was remanded back to the Assessing Officer for de novo assessment and adjudication.

The Tribunal considered the assessee's submission for withdrawal. The request was accepted, and the appeal was dismissed as withdrawn.

The Tribunal condoned the delay, citing the liberal interpretation of 'sufficient cause' to advance substantial justice. The issue of an addition for unexplained investment in a house property was set aside and restored to the AO for fresh adjudication, considering the daughter's potential financial contribution.

The Tribunal found that the CIT(A) passed the order without considering relevant material and submissions, violating principles of natural justice. Therefore, the matter was remanded back to the CIT(A) for fresh adjudication on merits.

The Tribunal held that interest earned on ADB loans parked in FDRs is not revenue in nature and therefore not taxable. However, the addition of prior period expenses was remitted back to the AO for re-examination due to incomplete facts presented to the revenue authorities.

The Tribunal held that the issue of conversion charges and interest is a mixed question of law and fact, requiring factual investigation, and thus additional grounds were not admitted. However, penalties under Section 271(1)(c) were deleted as the issue was debatable and consistent with prior years' decisions.

The Tribunal held that the issue of conversion charges and interest is a mixed question of law and fact, requiring factual investigation, and thus additional grounds were not admitted. However, penalties under Section 271(1)(c) were deleted as the issue was debatable and consistent with prior years' decisions.

The Tribunal held that the issue of conversion charges and interest is a mixed question of law and fact, requiring factual investigation, and thus additional grounds were not admitted. However, penalties under Section 271(1)(c) were deleted as the issue was debatable and consistent with prior years' decisions.

The Tribunal held that the issue of conversion charges and interest is a mixed question of law and fact, requiring factual investigation, and thus additional grounds were not admitted. However, penalties under Section 271(1)(c) were deleted as the issue was debatable and consistent with prior years' decisions.

The Tribunal held that the delay of over ten years was inordinate, unexplained, and not supported by a reasonable cause. Citing Supreme Court judgments, the Tribunal refused to condone the delay.

The Tribunal held that the delay was inordinate, unexplained, and lacked sufficient cause. The assessee failed to provide any cogent explanation or evidence to justify the delay.

The Tribunal held that mere issuance of Form 3 under the Vivad Se Vishwas Scheme is insufficient for automatic withdrawal of an appeal if subsequent mandatory requirements are not met. The CIT(A) should have verified the finality of the settlement before dismissing the appeal.

The Tribunal held that the CIT(A) should have adjudicated the issues on merits, especially the crucial contention regarding the bank account ownership. The matter was restored to the CIT(A) for fresh adjudication.

The Tribunal held that the CIT(Exemptions) should have considered the allowance for expenditure up to 5% on religious purposes by a charitable organization. The appeals were remanded back to the CIT(Exemptions) for reconsideration of the facts and verification of religious expenditure within the permissible limit.

The Tribunal held that the penalty was levied by the AO on September 16, 2024, which was before April 1, 2025. As per Section 271D(2), penalties imposable before April 1, 2025, could only be imposed by the Joint Commissioner, not the AO. Therefore, the penalty was unsustainable due to lack of jurisdiction.

The Tribunal upheld the addition, agreeing that since the premium exceeded 20% of the sum assured, the maturity proceeds were taxable. The Act does not allow for claiming a loss on such insurance policies, and gross maturity receipts are brought to tax.

The Tribunal held that the reopening of the assessment was based on incorrect facts and that Section 147 Explanation 2(a) was wrongly invoked. The Tribunal also found no corroborating evidence to support the addition on merits.

The Tribunal condoned the delay, citing the liberal interpretation of 'sufficient cause' to advance substantial justice. The Tribunal found that the deposits in the bank account were from the sale proceeds of agricultural land and deleted the addition.

The Tribunal held that the Rs. 93 lacs was not unexplained credit but a mistake in accounting for sale proceeds of a flat. It also allowed interest expenses on personal loans used for business and directed the AO to calculate admissible interest on the house loan under Section 24. The disallowance for non-deduction of TDS on professional fees below the threshold was also deleted.

The Tribunal held that the assessment order was without jurisdiction. Regarding the first issue, even if the Revenue could not ascertain the assessee's latest address from the PAN records, issuing a notice on the last known address (Panchkula) would imply that the AO at Panchkula had jurisdiction. However, the subsequent transfer of the case to ITO, Ward 6(5), Mohali was not in accordance with Section 127. The Tribunal relied on the Gujarat High Court's decision in P.V. Joshi Vs CIT, which held that jurisdiction cannot be conferred by consent. The AO has no power to transfer a case to another AO; this power vests with the Competent Authority as per Section 127. Since the notice under Section 148 was not issued by ITO, Ward 6(5), Mohali within the time limit prescribed under Section 149, the assessment order is not sustainable. Consequently, the assessment order was quashed, and the additions made to the assessee's income were deleted. The Stay Application became redundant and was rejected.

The Tribunal held that the assessee should not be considered in default for furnishing inaccurate particulars or concealment of income, as the excess refund was voluntarily repaid with interest before the notice under section 148. The Tribunal followed its previous decisions where similar penalties were deleted under identical circumstances.

The Tribunal held that since the assessee voluntarily corrected the mistake and paid the due tax with interest before the issuance of notice, the penalty was not leviable. The Tribunal followed its previous decisions in similar cases where penalties were deleted under identical circumstances.

The Tribunal held that Section 234E late fees could only be levied for statements processed after June 1, 2015, as the amendment to Section 200A making this possible was prospective. Therefore, the levy in this case, processed prior to that date, was invalid.

The Tribunal held that the assessee should not be considered in default for furnishing inaccurate particulars or concealment of income, as the excess refund was voluntarily repaid with interest before the notice under section 148. The Tribunal followed its previous decisions where similar penalties were deleted under identical circumstances.

The Tribunal held that the assessee had discharged the onus of explaining the source of payment by providing documentary evidence like gift deeds. The AO had not considered these documents, and there was no rebuttal to them.

The Tribunal held that the GST interest paid was compensatory for late payment of GST and not penal. Therefore, the disallowance made by the AO was incorrect.

The Tribunal condoned the delay in filing the appeal and, after reviewing the supporting documents provided by the assessee, found that the sources of the impugned credit were fully explained. The addition was directed to be deleted.

The Tribunal held that separate additions for unaccounted purchases and sales could not be sustained as they have a one-to-one correlation. It directed the AO to apply a profit rate of 3% on the unaccounted transactions and deleted certain other additions.

The Tribunal held that separate additions for unaccounted purchases and sales could not be sustained as they have a one-to-one correlation. It directed the AO to apply a profit rate of 3% on the unaccounted transactions and deleted certain other additions.

The Tribunal held that separate additions for unaccounted purchases and sales could not be sustained as they have a one-to-one correlation. It directed the AO to apply a profit rate of 3% on the unaccounted transactions and deleted certain other additions.

The Tribunal held that separate additions for unaccounted purchases and sales could not be sustained as they have a one-to-one correlation. It directed the AO to apply a profit rate of 3% on the unaccounted transactions and deleted certain other additions.

The Tribunal held that additions based on documents and digital data recovered from third parties, who were not employees or directors of the assessee, lacked direct link and corroboration with the assessee's business. The Tribunal also noted potential double addition and lack of satisfaction by the AO.

The Tribunal dismissed the revenue's appeal, confirming the CIT(A)'s relief on additions related to unaccounted sales of plots and SCOs. The Tribunal also allowed the assessee's appeal by deleting additions for alleged unaccounted receipts and unexplained expenditures, finding the basis for these additions to be unsubstantiated.

The Tribunal held that while the AO's invocation of presumptions under Section 132(4A) and 292C was justified for unaccounted purchases, separate additions for unaccounted purchases and gross profit on unaccounted sales could not be sustained. The profit element on unaccounted sales was restricted to 3%.

The Tribunal held that while the AO's invocation of presumptions under Section 132(4A) and 292C was justified for unaccounted purchases, separate additions for unaccounted purchases and gross profit on unaccounted sales could not be sustained. The profit element on unaccounted sales was restricted to 3%.

The Tribunal held that while the AO's invocation of presumptions under Section 132(4A) and 292C was justified for unaccounted purchases, separate additions for unaccounted purchases and gross profit on unaccounted sales could not be sustained. The profit element on unaccounted sales was restricted to 3%.

The Tribunal held that while the AO's invocation of presumptions under Section 132(4A) and 292C was justified for unaccounted purchases, separate additions for unaccounted purchases and gross profit on unaccounted sales could not be sustained. The profit element on unaccounted sales was restricted to 3%.

The Tribunal held that while the AO's invocation of presumptions under Section 132(4A) and 292C was justified for unaccounted purchases, separate additions for unaccounted purchases and gross profit on unaccounted sales could not be sustained. The profit element on unaccounted sales was restricted to 3%.

The Tribunal held that while the AO's invocation of presumptions under Section 132(4A) and 292C was justified for unaccounted purchases, separate additions for unaccounted purchases and gross profit on unaccounted sales could not be sustained. The profit element on unaccounted sales was restricted to 3%.

The Tribunal held that while the AO's invocation of presumptions under Section 132(4A) and 292C was justified for unaccounted purchases, separate additions for unaccounted purchases and gross profit on unaccounted sales could not be sustained. The profit element on unaccounted sales was restricted to 3%.

The Tribunal held that while the AO's invocation of presumptions under Section 132(4A) and 292C was justified for unaccounted purchases, separate additions for unaccounted purchases and gross profit on unaccounted sales could not be sustained. The profit element on unaccounted sales was restricted to 3%.