ITAT Delhi Judgments — April 2026

The Tribunal found that the lower authorities relied on mere assumptions rather than specific incriminating material to prove the on-money payment. Consequently, the addition made by the Revenue was deleted.

The Tribunal held that the inordinate delay of four years in recording satisfaction and issuing notice under Section 153C was not justified. Consequently, the proceedings were quashed on this ground.

The Tribunal held that the penalty order was unsustainable as the AO failed to consider the assessee's application for immunity. The AO was directed to decide the immunity application first, and if accepted, no penalty would be required.

The ITAT condoned the 617-day delay in filing the first appeal before the CIT(A) subject to a payment of Rs. 2000/-. Since both the AO's and CIT(A)'s orders were ex-parte, the matter was restored to the AO for de-novo assessment.

The Tribunal held that the CIT(E) should have provided an opportunity to the assessee to produce documents and decide the application on its merits. The impugned orders were set aside.

The Tribunal held that the CIT(E) should have provided an opportunity to the assessee to produce documents and decide the application on its merits. The impugned orders were set aside.

The Tribunal found that the CIT(Exemption) rejected the application without providing an opportunity of being heard to the assessee. Therefore, the impugned order was set aside.

The ITAT condoned the delay in filing the appeal, citing the interest of justice and equity. The tribunal found that the CIT(A) had passed an ex-parte order without hearing the assessee, violating principles of natural justice.

The Tribunal held that the CIT(A) passed the order ex-parte, violating principles of natural justice by not providing a hearing. Therefore, the matter was remanded back to the CIT(A) for a fresh decision on merits after affording an opportunity of hearing to the assessee.

The Tribunal held that assessment orders made through e-proceedings must be digitally signed by the Assessing Officer as per CBDT instructions. Failure to do so renders the assessment order invalid.

The Tribunal found both the AO's and CIT(A)'s orders were ex-parte and the CIT(A) failed to decide all appeal grounds on merits. Consequently, the issue was restored to the AO for a de-novo assessment, ensuring an opportunity of being heard for the assessee.

The Tribunal restored the issue of sundry creditors to the AO for verification, directing deletion of the addition if the assessee's claim of payment or offering to tax in later years is found correct. The appeals were disposed of based on this and other grounds.

The Tribunal held that the consultancy payments were genuine business expenses, supported by agreements and TDS deductions. It also found that the increased vehicle loan interest was due to full-year interest on assets purchased in prior years, not excessive expenditure.

The Tribunal restored the issue of sundry creditors to the AO for verification, directing deletion of the addition if the assessee's claim of payment or offering to tax in later years is found correct. The appeals were disposed of based on this and other grounds.

The Tribunal held that even though the assessee was not a party to the settlement proceedings, the addition of cash could not be made in the hands of the assessee as the group company had owned up the cash. Therefore, the order of the CIT(A) deleting the addition was upheld.

The Tribunal held that the interest received under Section 28 of the Land Acquisition Act is an accretion to the value and part of enhanced compensation, not income from other sources. The Tribunal distinguished the cited High Court judgments and affirmed the Supreme Court's view in Ghanshyam HUF.

The Tribunal held that the interest received under Section 28 of the Land Acquisition Act is an integral part of enhanced compensation and exempt under Section 10(37), following Supreme Court decisions. The Tribunal distinguished contrary High Court rulings by noting they overlooked subsequent Supreme Court affirmations.

The Tribunal held that the penalty order was passed beyond the limitation period prescribed under Section 275(1)(c) of the Income Tax Act. Therefore, the penalty order was quashed.

The Tribunal held that the penalty order was unsustainable as the AO failed to consider the assessee's application for immunity. The AO was directed to decide the immunity application first, and if accepted, no penalty would be required.

The Tribunal held that the inordinate delay of four years in recording satisfaction and issuing notice under Section 153C was not justified. Consequently, the proceedings were quashed on this ground.

The Tribunal upheld the deletion of the addition for unexplained investment, finding it to be a refund of an advance. It also upheld the deletion of the addition for bogus purchases, as there was no evidence of garment trading and the assessee's business was auto parts export.

The Tribunal held that a jurisdictional issue goes to the root of the assessment and, if decided on admitted facts, deserves consideration regardless of the stage. Since no order under Section 127 was passed, the transfer of jurisdiction was invalid, vitiating the assessment.

The Tribunal held that the notice issued on April 1, 2021, was invalid as it was issued after the substitution of Section 148 by the Finance Act, 2021, and the mandatory procedure under Section 148A was not followed. The notice was also considered barred by limitation.

The Tribunal restored the issue to the file of the AO for a de novo assessment, directing the AO to provide an opportunity of being heard and consider documents. The assessee was also directed to participate in the proceedings.

The Tribunal held that the assessment year in question (2015-16) fell outside the six-year period stipulated for reopening under Section 153C, as the satisfaction note was recorded and notice issued in FY 2021-22. The period of six years for reopening thus terminated with AY 2016-17.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that penalties levied under sections 271D and 271E are dependent on the quantum assessment order. Since the quantum orders were struck down, the penalties levied based on them cannot survive independently.

The Tribunal held that the notice issued under Section 148 was bad in law because the prior approval was not obtained from the specified authority as required by Section 151 of the Act. Consequently, the notice and the assessment order were quashed.

The Tribunal found that the assessee possessed documents that could establish a nexus between the interest outgo and the business. However, the Assessing Officer and CIT(A) had not clearly established this nexus. Therefore, the matter was remanded back to the Assessing Officer for a fresh assessment.

The Tribunal partly allowed the Revenue's appeals. It upheld the CIT(A)'s decision regarding disallowance of expenses related to short TDS deduction, stating that Section 40(a)(ia) is not applicable in such cases. However, it dismissed the Revenue's ground regarding interest on late TDS deposit as infructuous, as the assessee had accepted the disallowance.

The Tribunal partly allowed the Revenue's appeals. It upheld the CIT(A)'s decision regarding disallowance of expenses related to short TDS deduction, stating that Section 40(a)(ia) is not applicable in such cases. However, it dismissed the Revenue's ground regarding interest on late TDS deposit as infructuous, as the assessee had accepted the disallowance.

The Tribunal partly allowed the Revenue's appeals. It upheld the CIT(A)'s decision regarding disallowance of expenses related to short TDS deduction, stating that Section 40(a)(ia) is not applicable in such cases. However, it dismissed the Revenue's ground regarding interest on late TDS deposit as infructuous, as the assessee had accepted the disallowance.

The Tribunal held that the lower authorities erred in treating the accepted rent and interest receipts as unexplained money under Section 69A. The addition made on this basis was reversed.

The Tribunal acknowledged the possibility of communication gaps and, in the interest of justice, restored the appeal to the CIT(A) for fresh adjudication. The assessee was given three effective opportunities for hearing.

The Tribunal acknowledged the possibility of communication gaps in the virtual hearing mechanism. Therefore, in the interest of justice, the appeal was restored to the CIT(A)/NFAC for fresh adjudication.

The Tribunal condoned the delay in filing the appeal before the CIT(A), citing the principle of substantial justice over technicalities. The appeal was restored to the CIT(A) for fresh adjudication.

The Tribunal condoned the delay in filing the appeal before the CIT(A), referencing the principle of substantial justice over technicalities. The appeal was restored to the CIT(A) for fresh adjudication.

The Tribunal condoned the delay, considering the Covid-19 pandemic period and the unrebutted claim of belated order receipt. It further directed the Assessing Officer to recompute the salary income based on the Form 16A figure of Rs. 33,06,665/-, finding merit in the assessee's grievance.

The Tribunal restored the appeal to the CIT(A) for fresh adjudication, allowing three effective opportunities for hearing to the assessee.

The Tribunal held that the CIT(A)'s reliance on the Supreme Court decision was misplaced as it was distinguishable on facts. The Tribunal found no reason to deviate from its previous consistent rulings allowing depreciation on intangible assets for the assessee.