ITAT Dehradun Judgments — July 2026

The Tribunal condoned the 197-day delay in filing before the ITAT and set aside the ex-parte orders of the CIT(A). The matters were restored to the CIT(A) for fresh adjudication after providing the assessee an effective opportunity of being heard.

The Tribunal held that the assessee's activities did not extend for nine months in India, considering the commencement of actual work and the exclusion of the monsoon period. Therefore, no installation PE was established under the DTAA.

The Tribunal condoned the 197-day delay in filing before the ITAT and set aside the ex-parte orders of the CIT(A). The matters were restored to the CIT(A) for fresh adjudication after providing the assessee an effective opportunity of being heard.

The Tribunal condoned the 197-day delay in filing before the ITAT and set aside the ex-parte orders of the CIT(A). The matters were restored to the CIT(A) for fresh adjudication after providing the assessee an effective opportunity of being heard.

The Tribunal held that the assessee's activities did not extend for nine months in India, considering the commencement of actual work and the exclusion of the monsoon period. Therefore, no installation PE was established under the DTAA.

The ITAT condoned the delay in filing the appeal before the CIT(A), setting aside the CIT(A)'s order. The matter was remanded back to the CIT(A) for fresh adjudication on merits after providing the assessee an opportunity to be heard.

The Tribunal found merit in the assessee's grievance that the basis for the addition was not properly confronted. To ensure substantive justice, the matter was remanded back to the AO for fresh assessment.

The tribunal held that the additions were made based on a 'dumb document' (loose sheet of paper) seized from a third party, without independent verification or opportunity for cross-examination. The tribunal followed its own co-ordinate bench decisions which had deleted similar additions on identical facts.

The tribunal held that the additions were made based on a 'dumb document' (loose sheet of paper) seized from a third party, without independent verification or opportunity for cross-examination. The tribunal followed its own co-ordinate bench decisions which had deleted similar additions on identical facts.

The Tribunal condoned the delay, holding that dismissing an appeal for non-prosecution is not appropriate as it infringes upon the assessee's right to a fair order. The matter was remanded to the CIT(A) for fresh adjudication.

The tribunal held that the additions were made based on a 'dumb document' (loose sheet of paper) seized from a third party, without independent verification or opportunity for cross-examination. The tribunal followed its own co-ordinate bench decisions which had deleted similar additions on identical facts.

The Tribunal held that filing Form 10CCB within the stipulated date is directory, not mandatory, citing judicial precedents. The denial of deduction solely on this ground was considered overly technical.

The Tribunal condoned the delay in filing the appeals and, while noting the assessee's casual approach, decided to provide a fair hearing. The impugned orders were set aside and remanded to the CIT(A) for fresh adjudication.

The Tribunal acknowledged the assessee's casual approach and imposed a cost of Rs. 5000/-. However, to ensure a fair hearing, the Tribunal set aside the ex-parte order and remanded the case back to the CIT(A) for fresh adjudication.

The Tribunal, considering the lack of opportunity for the assessee to be heard, set aside the impugned orders. The matter was remitted back to the AO for a fresh assessment with ample opportunities for the assessee.

The Tribunal noted the substantial delay in filing the appeal before the CIT(A). The assessee contended that the assessment order was never properly served, despite being uploaded on the ITBA portal.

The Tribunal held that for F&O transactions settled otherwise than by actual delivery, the turnover should be considered only with respect to the profit or loss, not the gross sales and purchases. Since the assessee's actual loss was within the threshold, Section 44AB was not applicable.

The Tribunal restored both issues to the file of the Assessing Officer for fresh verification. The AO is to examine bills, vouchers, and ledgers for the 'other expenses' disallowance and verify the reconciliation for the service tax figure mismatch.

The Tribunal held that in the interest of natural justice, the assessee should be given an opportunity to present its facts before the CIT(E). The CIT(E) needs to examine these facts before deciding on the approval.

The Tribunal set aside the impugned order and remanded the matter back to the Ld. CIT(A) for fresh adjudication. The assessee will be given an ample opportunity to be heard and present their case.

The CIT(A) rightly deleted the addition, finding that the assessee had provided sufficient evidence to explain the cash deposits. The Tribunal affirmed the CIT(A)'s order, noting that the evidence was not new and did not violate Rule 46A.

The Tribunal condoned the delay in filing the appeals and, while noting the assessee's casual approach, decided to provide a fair hearing. The impugned orders were set aside and remanded to the CIT(A) for fresh adjudication.

The Tribunal held that consultancy receipts by professors from IIT Roorkee, similar to previous cases, should be treated as income from other sources and allowed the claim of 15% expenses. The lower authorities' actions were reversed.

The Tribunal condoned the delay, holding that dismissing an appeal for non-prosecution is not appropriate as it infringes upon the assessee's right to a fair order. The matter was remanded to the CIT(A) for fresh adjudication.

The Tribunal found prima facie evidence that the house was constructed and fit for habitation within the time allowed for capital gains exemption. The matter was remanded to the AO for verification of fresh evidence submitted by the assessee.

The Tribunal found the assessee's cause for delay to be reasonable, as they were unaware of the assessment order. The Tribunal condoned the delay and remitted the matter back to the Assessing Officer for fresh adjudication.

The Tribunal set aside the ex parte orders of the CIT(A) and remanded the matters back for fresh adjudication. The CIT(A) was directed to consider a coordinate bench's order for AY 2017-18 and provide an opportunity of hearing for AY 2020-21.

The Tribunal held that the reassessment proceedings for AYs 2016-17 to 2018-19 were invalid as the notice under section 148 was issued beyond three years based on third-party data treated as the assessee's books of account. Furthermore, the Tribunal found that the denial of the assessee's request for cross-examination of persons whose statements were relied upon violated the principles of natural justice.

The Tribunal accepted the assessee's submission to reduce the sustained addition. The addition was further reduced from Rs. 8,00,000/- to Rs. 3,00,000/-.

The Tribunal set aside the ex parte orders of the CIT(A) and remanded the matters back for fresh adjudication. The CIT(A) was directed to consider a coordinate bench's order for AY 2017-18 and provide an opportunity of hearing for AY 2020-21.

The Tribunal found that the CIT(A) did not properly consider the assessee's submissions, documentary evidence, and legal precedents. Therefore, the matter was restored to the CIT(A) for fresh adjudication.

The Tribunal held that the assessee's explanation constituted a sufficient cause for condoning the delay, emphasizing that substantial justice should not be defeated by technicalities. The impugned order of the CIT(A) was set aside.

The ITAT condoned the delay in filing the appeal, finding the assessee's explanation satisfactory. The Tribunal held that the CIT(A) order was passed without sufficient opportunity of hearing, violating principles of natural justice.

The Tribunal found that the CIT(A) did not properly consider the assessee's submissions, documentary evidence, and legal precedents. Therefore, the matter was restored to the CIT(A) for fresh adjudication.

The Tribunal held that the reassessment proceedings for AYs 2016-17 to 2018-19 were invalid as the notice under section 148 was issued beyond three years based on third-party data treated as the assessee's books of account. Furthermore, the Tribunal found that the denial of the assessee's request for cross-examination of persons whose statements were relied upon violated the principles of natural justice.

The Tribunal held that the reassessment proceedings for AYs 2016-17 to 2018-19 were invalid as the notice under section 148 was issued beyond three years based on third-party data treated as the assessee's books of account. Furthermore, the Tribunal found that the denial of the assessee's request for cross-examination of persons whose statements were relied upon violated the principles of natural justice.

The Tribunal held that the reassessment proceedings for AYs 2016-17 to 2018-19 were invalid as the notice under section 148 was issued beyond three years based on third-party data treated as the assessee's books of account. Furthermore, the Tribunal found that the denial of the assessee's request for cross-examination of persons whose statements were relied upon violated the principles of natural justice.

The Tribunal held that the reassessment proceedings for AYs 2016-17 to 2018-19 were invalid as the notice under section 148 was issued beyond three years based on third-party data treated as the assessee's books of account. Furthermore, the Tribunal found that the denial of the assessee's request for cross-examination of persons whose statements were relied upon violated the principles of natural justice.

The Tribunal held that the reassessment proceedings for AYs 2016-17 to 2018-19 were invalid as the notice under section 148 was issued beyond three years based on third-party data treated as the assessee's books of account. Furthermore, the Tribunal found that the denial of the assessee's request for cross-examination of persons whose statements were relied upon violated the principles of natural justice.

The Tribunal held that the reassessment proceedings for AYs 2016-17 to 2018-19 were invalid as the notice under section 148 was issued beyond three years based on third-party data treated as the assessee's books of account. Furthermore, the Tribunal found that the denial of the assessee's request for cross-examination of persons whose statements were relied upon violated the principles of natural justice.

The Tribunal held that the reassessment proceedings for AYs 2016-17 to 2018-19 were invalid as the notice under section 148 was issued beyond three years based on third-party data treated as the assessee's books of account. Furthermore, the Tribunal found that the denial of the assessee's request for cross-examination of persons whose statements were relied upon violated the principles of natural justice.

The Tribunal held that the CIT(Exemption) has the power to condone delays in filing Form 10AB if there is a reasonable cause. The reasons provided by the assessee for the delay were found to be sufficient.

The Tribunal held that the reasons provided by the assessee for the delay in filing Form 10AB were sufficient cause for condonation. Following a coordinate bench's decision, the Tribunal set aside the CIT's order and restored the application for fresh adjudication after condoning the delay.

The Tribunal condoned the delay in filing the appeals, citing the principle of substantial justice over technicalities. It held that the ex-parte orders were passed without providing an effective opportunity of hearing due to lack of proof of notice service.

The Tribunal held that the CIT(Exemption) has the power to condone delays in filing Form 10AB if there is a reasonable cause. The reasons provided by the assessee for the delay were found to be sufficient.

The Tribunal held that the reasons provided by the assessee for the delay in filing Form 10AB were sufficient and should be condoned. The impugned order of the CIT(Exemption) was set aside, and the matter was restored for de novo adjudication.

The ITAT found the CIT(A)'s approach hyper-technical and condoned the 43-day delay. The matter was set aside and remanded back to the CIT(A) for adjudication on merits.

The Tribunal held that the filing of Form 67 is a procedural requirement and not mandatory, and its belated filing should not preclude the assessee from claiming FTC. The provisions of the Double Taxation Avoidance Agreement (DTAA) override domestic law when more beneficial to the assessee.

The Tribunal set aside the CIT(A)'s order and remitted the matter back for fresh adjudication. The assessee was granted one more opportunity to present their case before the CIT(A).

The Tribunal held that the CIT(A) order was passed without an effective hearing, violating the principles of natural justice. Therefore, the order was set aside.