ITAT Cuttack Judgments — June 2026

The Tribunal held that the invocation of Section 269SS for the assessment year 2013-14 was illegal as the definition of 'specified sum' was substituted by the Finance Act, 2023, effective from 01.04.2023. Therefore, the penalty order and the CIT(A)'s order were quashed.

The Tribunal noted that the disallowance in AY 2006-07 was due to accounting treatment, while the invoices related to that year. The reversal in AY 2007-08 and subsequent rejection of rectification led to double taxation. The Tribunal followed the 'real income' theory and remitted the matter to the Assessing Officer.

The Tribunal held that statements recorded under section 132(4) are crucial evidence and cannot be discarded without proper justification, especially when not retracted promptly. The addition under section 69C for unexplained expenditure is valid even without rejecting the books of account under section 145(3) if the purchases are found to be non-genuine.

The Tribunal noted that the disallowance in AY 2006-07 was due to accounting treatment, while the invoices related to that year. The reversal in AY 2007-08 and subsequent rejection of rectification led to double taxation. The Tribunal followed the 'real income' theory and remitted the matter to the Assessing Officer.

The Tribunal held that statements recorded under section 132(4) are crucial evidence and cannot be discarded without proper justification, especially when not retracted promptly. The addition under section 69C for unexplained expenditure is valid even without rejecting the books of account under section 145(3) if the purchases are found to be non-genuine.

The Tribunal held that disallowance under Section 14A should be restricted to investments yielding exempt income. It also ruled that CSR expenses are allowable for the assessee as it is not registered under the Companies Act. Finally, it allowed provisions for salary, wages, and provident fund, stating they are ascertained liabilities under an approved accrual accounting framework.

The Tribunal held that since the assessee provided details of the transaction with the HUF, and the HUF itself admitted to paying the money, it could not be treated as undisclosed income of the assessee. Therefore, the additions made by the Assessing Officer and confirmed by the CIT(A) were deleted.

The Tribunal held that for a penalty under Section 271D to be validly imposed, the AO must record satisfaction regarding the violation of Section 269SS during the assessment proceedings. Since no such satisfaction was recorded by the AO in this case, the penalty was quashed.

The Tribunal restored the appeal to the Assessing Officer for fresh adjudication. This was to provide the assessee with an adequate opportunity to be heard and submit documents, subject to payment of costs.

The Tribunal held that denying the benefit of Sections 11 & 12 and taxing entire receipts under the head 'business' is not a permissible adjustment under Section 143(1). Therefore, the intimation and the order rejecting the rectification were quashed.

The Tribunal restored the appeal to the file of the CIT(A) for fresh adjudication. The assessee was directed to cooperate in the proceedings to provide one more opportunity for representation.

The Tribunal held that principles of natural justice should not be sacrificed for procedural lapses. Therefore, the delays in filing appeals before the CIT(A) were condoned.

The Tribunal condoned the delay in filing the appeal before the CIT(A) in the interest of justice. It held that the reassessment was done without proper examination of details and restored the issues to the Assessing Officer for readjudication with an opportunity for the assessee to be heard.

The Tribunal condoned the delay in filing the appeals. In the interest of justice, the matters were restored to the file of the Assessing Officer for fresh adjudication, subject to the assessee paying a cost of Rs. 10,000 in each case.

The Tribunal noted that the assessee admittedly had no registration prior to April 1, 2021, and that any granted registration cannot be withdrawn without a show-cause notice. The order of the CIT(Exemption) was set aside, and the issues were restored for adjudication after considering the assessee's evidence.

The Tribunal condoned the delay, holding that dismissing an appeal on technical grounds without considering merits goes against natural justice. They relied on Supreme Court judgments for a liberal approach to condonation of delay.

The Tribunal condoned the delay in filing the appeals and restored the matters to the Assessing Officer for fresh adjudication. This was subject to the assessee paying a cost of Rs. 10,000 in each case.

The tribunal restored the issues to the AO for fresh adjudication, allowing the assessee an opportunity to present all relevant facts, subject to a cost of Rs. 10,000.

The Tribunal held that the consolidated approvals were unsustainable as they lacked evidence of the approving authority's thought process and were granted mechanically for multiple assessment years. Consequently, the approvals and consequential assessment orders were quashed.

The Tribunal restored the issue to the file of the CIT(E) for readjudication. The assessee was directed to rectify the mistake by filing a fresh application, recognizing that the incorrect mention of a section code should not be fatal to the registration claim.

The Tribunal condoned the delay in filing the appeal. The matter was restored to the Assessing Officer for fresh adjudication, subject to the assessee paying a cost of Rs. 10,000/-.

The Tribunal condoned the delay and restored the matter to the AO for readjudication. This was subject to the assessee paying a cost of Rs. 10,000/- to the ITAT Bar Association within 60 days.

The ITAT condoned the delay in filing the appeals before the CIT(A) and restored the matters to the CIT(A) for fresh adjudication on merits. The assessee was directed to furnish all necessary details.

The Tribunal restored the appeal to the file of the CIT(A) for fresh adjudication after giving the assessee an opportunity to be heard. The stay application was dismissed as infructuous.

The Tribunal held that the consolidated approvals were unsustainable as they lacked evidence of the approving authority's thought process and were granted mechanically for multiple assessment years. Consequently, the approvals and consequential assessment orders were quashed.

The Tribunal condoned the delay in filing the appeals. In the interest of justice, the matters were restored to the file of the Assessing Officer for fresh adjudication, subject to the assessee paying a cost of Rs. 10,000 in each case.

The Tribunal held that principles of natural justice should not be sacrificed for procedural lapses. Therefore, the delays in filing appeals before the CIT(A) were condoned.

The Tribunal condoned the delay in filing the appeal and restored the matter to the Assessing Officer for fresh adjudication. This was subject to the assessee paying a cost of Rs. 10,000/- and providing all necessary details.

The Tribunal restored the appeal to the file of the CIT(A) for fresh adjudication on merits. The assessee was directed to furnish all details before the CIT(A).

The Tribunal held that principles of natural justice should not be sacrificed for procedural lapses. Therefore, the delays in filing appeals before the CIT(A) were condoned.

The Tribunal condoned the delay in filing the appeals and restored the matters to the Assessing Officer for fresh adjudication. This was subject to the assessee paying a cost of Rs. 10,000 in each case.

The Tribunal held that principles of natural justice should not be sacrificed for procedural lapses. Therefore, the delays in filing appeals before the CIT(A) were condoned.

The Tribunal found that the assessee had produced details, but the Assessing Officer had not examined them. Therefore, in the interest of justice, the issues were restored to the Assessing Officer for re-adjudication.

The Tribunal condoned the delay in filing the appeals and restored the matters to the Assessing Officer for fresh adjudication. This was subject to the assessee paying a cost of Rs. 10,000 in each case.

The Tribunal held that the consolidated approvals were stereotype, lacked indication of the approving authority's thought process, and multiple approvals were given in a single letter, making them unsustainable. Consequently, the approvals and consequential assessment orders were quashed.

The Tribunal condoned the delay in filing the appeals and restored the matters to the Assessing Officer for fresh adjudication. This was subject to the assessee paying a cost of Rs. 10,000 in each case.

The ITAT condoned the delay in filing the appeals before the CIT(A) and restored the matters to the CIT(A) for fresh adjudication on merits. The assessee was directed to furnish all necessary details.

The Tribunal restored the matter to the CIT(E) for readjudication on merits. The assessee was directed to rectify the mistake by filing a fresh application.

The Tribunal condoned the delay and restored the matter to the AO for readjudication. This was subject to the assessee paying a cost of Rs. 10,000/- to the ITAT Bar Association, Odisha, Cuttack, within sixty days.

The ITAT held that the CIT(A)'s order was non-speaking and violated the provisions of Section 250(6) of the Act. The matter was restored to the CIT(A) for fresh adjudication with a speaking order.

The Tribunal held that the consolidated approvals were unsustainable as they lacked evidence of the approving authority's thought process and were granted mechanically for multiple assessment years. Consequently, the approvals and consequential assessment orders were quashed.

The Tribunal held that the consolidated approvals were unsustainable as they lacked evidence of the approving authority's thought process and were granted mechanically for multiple assessment years. Consequently, the approvals and consequential assessment orders were quashed.

The Tribunal restored the issues to the file of the AO for fresh adjudication after granting the assessee an opportunity to be heard. This was subject to the assessee paying a cost of Rs. 10,000/- to the ITAT Bar Association.

The Tribunal restored the issue to the AO for fresh adjudication after granting the assessee an opportunity to be heard, subject to payment of costs.

The tribunal noted that the defect in the appeal fee payment was not rectified by the assessee despite a notice. Consequently, the appeal was dismissed as infructuous.

The Tribunal condoned the delay and restored the matter to the Assessing Officer for fresh adjudication. This is subject to the assessee paying a cost of Rs. 10,000/-.

The Tribunal set aside the CIT(A)'s order and restored the issues to the Assessing Officer for fresh adjudication. The assessee was directed to cooperate and provide necessary evidence.

The Tribunal noted that the rejection was based on a technical error in mentioning the wrong section code. In the interest of justice, the matter was restored to the CIT(E) for readjudication on merits, with the assessee directed to file a fresh application to rectify the mistake.

The Tribunal condoned the delay and restored the issues to the CIT(A) for readjudication. The assessee will be granted an adequate opportunity to present evidence.

The Tribunal held that the penalty notice was defective as it did not specify the limb under which the penalty was being levied. This defect was considered incurable, rendering the penalty unsustainable.