ITAT Cuttack Judgments — September 2026

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the Additional Commissioner and the Assessing Officer, and demonstrated a non-application of mind. The Tribunal relied on the Hon'ble Supreme Court's decision in M/s Serajuddin & Co., which emphasized that the approving authority must show some indication of having examined the draft orders, even if elaborate reasons are not provided. The fact that multiple approvals were granted in a single letter further supported the finding of a lack of due diligence. The Tribunal also referred to the decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed by the assessees in response to notices under Section 153C/153A would remain valid, and the tax on the disclosed income would be recoverable.

The Tribunal held that the addition of Rs. 16,90,000/- as unexplained cash credit was not justified. The Tribunal noted that the assessee was a pensioner with no other income besides pension and interest. The Assessing Officer himself had accepted Rs. 2,50,000/- as a plausible source of cash holding. The Tribunal found no evidence to suggest the assessee earned any other income. The assessee's claim that the money was kept for his son's marriage was considered a plausible explanation that had not been found to be false. Therefore, the addition made by the Assessing Officer and confirmed by the CIT(A) was deleted. The ratio decidendi is that if an assessee provides a plausible explanation for cash deposits, and the revenue fails to disprove it or establish any other source of income, the addition under Section 69A is unwarranted.

The Tribunal held that the notice issued under Section 148A(b) of the Income Tax Act, 1961, was indeed invalid. A perusal of the facts revealed that the notice was dated March 14, 2024, and required compliance by March 21, 2024. This did not provide the statutory seven days' clear time to the assessee. The Tribunal found support for this view in the decision of the Hon'ble Jharkhand High Court in the case of Satish Kumar (W.P (T) No.2640 of 2023 dated 28.08.2023). Consequently, following the precedent set by the Jharkhand High Court, the Tribunal quashed the notice issued under Section 148A of the Act. As the assessment order was based on this invalid notice, it also stood quashed. The appeal of the assessee was allowed.

The Tribunal held that the approvals granted under Section 153D were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the Additional Commissioner and the Assessing Officer, and demonstrated a non-application of mind. The Tribunal relied on the Hon'ble Supreme Court's decision in M/s Serajuddin & Co., which emphasized that the approving authority must show some indication of having examined the draft orders, even if elaborate reasons are not provided. The fact that multiple approvals were granted in a single letter further supported the finding of a lack of due diligence. The Tribunal also referred to the decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed by the assessees in response to notices under Section 153C/153A would remain valid, and the tax on the disclosed income would be recoverable.

The Tribunal found no basis to estimate the profit at 20% of the turnover. It also found no basis to consider the Rs. 98,000/- as unexplained, disregarding the assessee's explanation. Considering the nature of the business, turnover, and the facts of the case, the Tribunal deemed it reasonable to estimate the assessee's income on a profit of 8% of the total turnover. This total turnover was to include Rs. 85,42,021/- plus Rs. 98,000/-, treating the latter as part of business proceeds. Consequently, the order of the Ld. CIT(A) was set aside, and the AO was directed to re-compute the income accordingly. The principle derived is that profit estimation must be reasonable and supported by evidence, and explanations for deposits should be considered. The Tribunal did not expressly leave any issue undecided.

The Tribunal held that the notice issued under Section 148 of the Income Tax Act is invalid and consequently quashed. The reasoning was based on the fact that the notice was issued on July 29, 2022, for the assessment year 2017-18, which is beyond three years from the end of the relevant assessment year. As per Section 151(ii) of the Act, for such cases, the approval must be granted by the Principal Chief Commissioner of Income Tax (Pr. CCIT). However, in this case, the approval was granted by the Principal Commissioner of Income Tax (Pr. CIT), Bhubaneswar. The Tribunal, respectfully following the decision of the Hon'ble Supreme Court in ITO vs. Prakash Pandurang Patil, found that the approval was granted by a lower authority and not the appropriate authority. Therefore, the notice issued under Section 148 was deemed invalid, and the consequential assessment also stood quashed. The appeal of the assessee was allowed.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked reference to any discussion between the authorities, and showed a non-application of mind. The Tribunal cited the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were given in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed.

The Tribunal held that the approvals granted under Section 153D were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked reference to any discussion between the authorities, and showed a non-application of mind. The Tribunal cited the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were given in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed.

The Tribunal held that the approvals granted under Section 153D were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked reference to any discussion between the authorities, and showed a non-application of mind. The Tribunal cited the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were given in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed.

The Tribunal held that the approvals granted under Section 153D were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked reference to any discussion between the authorities, and showed a non-application of mind. The Tribunal cited the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were given in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed.

The Tribunal held that the approvals granted under Section 153D were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked reference to any discussion between the authorities, and showed a non-application of mind. The Tribunal cited the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were given in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal held that the approvals granted under Section 153D were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked reference to any discussion between the authorities, and showed a non-application of mind. The Tribunal cited the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were given in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed.

The Tribunal held that the approvals granted under Section 153D of the Income Tax Act, 1961, were unsustainable and consequently quashed. The reasoning was based on the observation that the approval letters were stereotype, lacked any reference to discussions or issues considered between the approving authority and the Assessing Officer, and indicated a non-application of mind. The Tribunal relied on the Supreme Court's decision in M/s Serajuddin & Co., which emphasized the need for the approving authority to indicate its thought process and examine the draft orders. The fact that multiple approvals were granted in a single letter further supported the finding of non-application of mind. The Tribunal also referred to the Supreme Court's decision in DCIT vs. Sunil Kr. Sharma. As the approvals were quashed for want of sanctity, the consequential assessment orders were also quashed. However, the Tribunal clarified that the returns of income filed in response to notices under Section 153C/153A would remain valid, and the disclosed income would not be disturbed, with the tax on such disclosed income remaining recoverable.

The Tribunal noted that the assessee had filed written submissions before the CIT(A), but these were not considered. It was also observed that the assessment order had been passed ex parte. In the interest of justice, the Tribunal decided to restore the issues in the appeal to the file of the Assessing Officer for adjudication on merits. The assessee was to be provided with an adequate opportunity of being heard. The Tribunal did not decide the merits of the case but rather remanded it for fresh consideration. The specific relief granted was the restoration of the appeal to the Assessing Officer.

The Tribunal decided to condone the delay in filing the appeal before the CIT(A), emphasizing that substantial justice should prevail over technicalities. The Tribunal noted that the assessment order was passed ex parte and the assessee had failed to produce details before the AO. In the interest of justice, the Tribunal restored the issues to the file of the Assessing Officer for adjudication on merits. The assessee was to be provided with an adequate opportunity of being heard. The ratio decidendi is that procedural delays should not preclude substantive justice, and where an ex parte assessment has occurred due to non-production of details, restoration to the AO for a proper hearing is warranted. The operative direction is to restore the appeal to the AO.

The Tribunal acknowledged the assessee's plea regarding the COVID-19 pandemic and the ex-parte nature of the CIT(A)'s order. It decided to grant the assessee another opportunity to present their case.

The Tribunal acknowledged the assessee's plea regarding the COVID-19 pandemic and the ex-parte nature of the CIT(A)'s order. It decided to grant the assessee another opportunity to present their case.

The Tribunal acknowledged the assessee's plea regarding the COVID-19 pandemic and the ex-parte nature of the CIT(A)'s order. It decided to grant the assessee another opportunity to present their case.

The ITAT upheld the disallowance, confirming that the expenses, such as those for mobile phones, chain link net, and GI wire, were capital in nature as they provided enduring benefits or enhanced fixed assets, rather than being recurring revenue expenses.

The Tribunal found that an error had indeed crept into the assessment order regarding the loan and gold loan amounts. Upon correction of these figures, the addition made by the Assessing Officer was automatically deleted.

The Tribunal upheld the order of the CIT(A), stating that the assessee failed to produce any documentary evidence to satisfactorily explain the nature and source of the cash deposits, even before the Tribunal.

The Tribunal condoned the delay in filing the appeals. In the interest of justice, the matters were restored to the file of the CIT(A) for re-adjudication, granting the assessee an adequate opportunity of being heard.

The Tribunal condoned the delay in filing the appeal before the CIT(A) in the interest of substantial justice. The matter was restored to the CIT(A) for re-adjudication on merits after providing the assessee an opportunity to be heard.

The Tribunal held that the assessee had sufficiently substantiated the source of investment with documentary evidence like returns and ledger accounts of relatives. However, the interest paid on loans for the house property was not allowable as it was not related to the assessee's business.

The Tribunal acknowledged the assessee's imprisonment and the need for an adequate opportunity to be heard. Therefore, the appeals were restored to the Assessing Officer for re-adjudication.

The Tribunal acknowledged the assessee's situation of being in jail and the need for an adequate opportunity to be heard. Therefore, the appeals were restored to the Assessing Officer for re-adjudication.

The Tribunal acknowledged that the assessee was in jail and deserved an adequate opportunity to be heard. Therefore, the appeals were restored to the Assessing Officer for re-adjudication.

The Tribunal acknowledged that the assessee was in jail and should be given an adequate opportunity to be heard. Therefore, the issues were restored to the Assessing Officer for re-adjudication.

The Tribunal acknowledged that the assessee was in jail and should be given an adequate opportunity to be heard. Therefore, the issues were restored to the Assessing Officer for re-adjudication.

The Tribunal acknowledged that the assessee was in jail and should be given an adequate opportunity to be heard. Therefore, the issues were restored to the Assessing Officer for re-adjudication.

The Tribunal held that the amounts deposited in the bank account were disclosed in the assessee's cash book, which tallied with business transactions and was not disputed by the revenue. Since the cash book formed the basis for the returned income, the deposits could not be treated as unexplained income.

The Tribunal condoned the delay in filing the appeals. In the interest of justice, the matters were restored to the file of the CIT(A) for re-adjudication, granting the assessee an adequate opportunity of being heard.

The Tribunal noted that the CIT(A) had not examined the assessee's explanations in detail. Therefore, to ensure justice, the assessee was granted another opportunity to submit evidence before the CIT(A) for fresh adjudication.

The Tribunal held that the addition was based solely on a Telegram chat not found in the assessee's possession or involving its partners. Since no statements were recorded from the parties involved in the chat and the Assessing Officer had not made any additions earlier despite knowing about the evidence, the enhancement was deemed unjustified.

The tribunal held that the notice issued under Section 148A(b) was invalid as it did not provide the mandatory 7 days' clear time for compliance. Consequently, the assessment order based on this invalid notice was also quashed.

The Tribunal set aside the CIT(A)'s order and remanded the case for re-adjudication on merits. The assessee is directed to file a reply, and the CIT(A) must strictly comply with Rule 46A regarding admission of additional evidence.