ITAT Cochin Judgments — May 2026

The Tribunal held that for concluded assessment years, additions can only be made based on incriminating material found during a search. Since the additions were based on material furnished by the assessee during assessment proceedings and not on search findings, they were not sustainable.

The Tribunal held that for concluded assessment years, additions can only be made based on incriminating material found during a search. Since the additions were based on material furnished by the assessee during assessment proceedings and not on search findings, they were not sustainable.

The Tribunal upheld the rejection of the Section 80P deduction due to non-compliance with Section 80A(5). However, it deleted the penalty under Section 271B, finding a reasonable cause for the delay in filing the audit report.

The Tribunal condoned the delay in filing the appeal before the CIT(A), acknowledging the assessee's lack of familiarity with e-filing procedures and entrusting the task to a legal practitioner. The case was remitted back to the CIT(A) for adjudication on merits.

The Tribunal dismissed the appeal due to a delay of 545 days in filing it. The petition for condonation of delay was rejected, as the reason provided (outsourcing work) was unsubstantiated with evidence, and the Tribunal noted that a litigant who sleeps over their rights should not be granted extraordinary relief.