ITAT Delhi Judgments — April 2026

The Tribunal held that the assessee was not granted an effective opportunity of hearing by the CIT(A) and the assessment order was also ex-parte. Therefore, the matter was remitted back to the AO for a limited purpose.

The Tribunal quashed the reopening for AY 2013-14 as it was based on a change of opinion. For AY 2017-18, the Tribunal found that while the assessee failed to prove abnormal cash sales, the lower authorities did not pinpoint specific defects in the books, leading to a partial allowance.

The Tribunal held that the reopening of assessments was not sustainable in law as it was based on conjectures and surmises rather than tangible material. The Tribunal emphasized that statements from searches alone, without corroborative evidence, are insufficient to initiate reassessment proceedings.

The Tribunal condoned the significant delay in filing the appeals, accepting the medical emergency of the managing trustee as a sufficient cause. The Tribunal set aside the impugned orders and remitted the matter back to the CIT(Exemption) to grant the assessee one more opportunity to submit the necessary documents.

The Tribunal held that the reopening of assessments was not sustainable in law as it was based on conjectures and surmises rather than tangible material. The Tribunal emphasized that statements from searches alone, without corroborative evidence, are insufficient to initiate reassessment proceedings.

The Tribunal held that the absence of an irrevocable clause in the trust deed was a valid ground for rejection of registration under Section 12A(1)(ac)(iii). Consequently, the approval under Section 80G was also rightly rejected.

The Tribunal upheld the CIT(A)'s order, finding that the assessee had provided sufficient evidence to establish the identity, creditworthiness, and genuineness of the loan transaction. The Revenue failed to controvert the findings of the CIT(A).

The Tribunal held that the appeal was decided ex-parte without providing the assessee an opportunity to be heard. Therefore, the matter was restored to the NFAC for a decision on merits after granting a final opportunity to the assessee.

The Tribunal held that the reopening of assessments was not sustainable in law as it was based on conjectures and surmises rather than tangible material. The Tribunal emphasized that statements from searches alone, without corroborative evidence, are insufficient to initiate reassessment proceedings.

The Tribunal held that the absence of an irrevocable clause in the trust deed was a valid ground for rejection of registration under Section 12A(1)(ac)(iii). Consequently, the approval under Section 80G was also rightly rejected.

The Tribunal held that the CIT(A) failed to adjudicate the grounds raised by the assessee on the merits of the additions/disallowances. Therefore, the appeals were restored to the file of the CIT(A) for fresh adjudication.

The Tribunal found that the CIT(A) had not adjudicated the grounds on merits. Therefore, the appeals were set aside and restored to the file of the CIT(A) for fresh adjudication on all grounds.

The Tribunal found that the CIT(A) had not adjudicated the grounds on merits. Therefore, the appeals were set aside and restored to the file of the CIT(A) for fresh adjudication on all grounds.

The Tribunal held that the delay was not supported by cogent reasons and was not due to circumstances beyond the assessee's control. The Tribunal noted that the assessee was served a copy of the lower appellate order.

The Tribunal condoned the delay, finding reasonable cause for the assessee's inability to file on time. The appeal was then restored to the CIT(A) for a fresh decision after providing the assessee with an adequate opportunity to be heard.

The Tribunal found that the CIT(A) had not adjudicated the grounds on merits. Therefore, the appeals were set aside and restored to the file of the CIT(A) for fresh adjudication on all grounds.

The Tribunal allowed the assessee's appeal on the Section 14A disallowance, holding that investments were made from own surplus funds. It also upheld the deletion of disallowance for warranty provisions, following previous consistent rulings. The Revenue's appeal was dismissed.

The Tribunal held that the CIT(A) failed to adjudicate the grounds raised by the assessee on the merits of the additions/disallowances. Therefore, the appeals were restored to the file of the CIT(A) for fresh adjudication.

The Tribunal held that 'on money' received from the sale of an immovable property should be treated as part of the sale consideration and taxed under the head 'Income from Capital Gains', not as unexplained money under Section 69A.

The Tribunal held that 'on money' received from the sale of immovable property should be treated as part of the sale consideration and taxed under the head 'Income from Capital Gains', not as unexplained money under Section 69A.

The Tribunal held that the CIT(A) failed to adjudicate the grounds raised by the assessee on the merits of the additions/disallowances. Therefore, the appeals were restored to the file of the CIT(A) for fresh adjudication.

The Tribunal held that the reassessment proceedings were invalid because the additions made were not based on the reasons recorded for reopening. The Tribunal relied on judicial precedents to quash the impugned reopening.

The Tribunal found that the CIT(A) had not adjudicated the grounds on merits. Therefore, the appeals were set aside and restored to the file of the CIT(A) for fresh adjudication on all grounds.

The Tribunal held that the CIT(A) failed to adjudicate the grounds raised by the assessee on the merits of the additions/disallowances. Therefore, the appeals were restored to the file of the CIT(A) for fresh adjudication.

The Tribunal set aside the issue of excess cash found at business premises to the AO for reconciliation, directing that no addition be made if cash sales claims are correct. Regarding cash found with a third party, the AO was directed to apply a 20% GP rate on such cash sales.

The Tribunal found that the CIT(A) had not adjudicated the grounds on merits. Therefore, the appeals were set aside and restored to the file of the CIT(A) for fresh adjudication on all grounds.

The Tribunal held that the approval granted by the PCIT was mechanical, merely recording 'yes', and did not reflect an independent application of mind. Therefore, the assumption of jurisdiction was vitiated.

The Tribunal held that Section 56(2)(viib) is not applicable as no fresh consideration was received during the year of allotment; the shares were issued in lieu of pre-existing CCDs. Furthermore, the Tribunal ruled that the balance sheet as of March 31, 2016, was correctly used for valuation as the consideration for the CCDs was received in the preceding assessment year.

The Tribunal found that the CIT(A) had not adjudicated the grounds on merits. Therefore, the appeals were set aside and restored to the file of the CIT(A) for fresh adjudication on all grounds.

The Tribunal found that the CIT(A) had sustained additions by addressing only grounds on merits, ignoring various legal grounds raised by the assessee. Therefore, the appeals were restored to the CIT(A) for fresh adjudication of all grounds.

The Tribunal observed that the CIT(A) had sustained additions by addressing only grounds on merits, ignoring various legal grounds raised by the assessee. Therefore, the appeals were restored to the CIT(A) for a fresh decision on all grounds.

The Tribunal set aside the issue of excess cash found at business premises to the AO for reconciliation, directing that no addition be made if cash sales claims are correct. Regarding cash found with a third party, the AO was directed to apply a 20% GP rate on such cash sales.

The Tribunal set aside the issue of excess cash found at business premises to the AO for reconciliation, directing that no addition be made if cash sales claims are correct. Regarding cash found with a third party, the AO was directed to apply a 20% GP rate on such cash sales.

The Tribunal held that 'on money' received from the sale of immovable property should be treated as part of the sale consideration and taxed under the head 'Income from Capital Gains', not as unexplained money under Section 69A.

The Tribunal found that the CIT(A) had not adjudicated the grounds on merits. Therefore, the appeals were set aside and restored to the file of the CIT(A) for fresh adjudication on all grounds.

The Tribunal held that the assessments were barred by limitation as they were completed on March 18, 2016, which is beyond the one-year period from the end of the financial year in which the Section 148 notice was served (i.e., March 31, 2015). Therefore, the assessments were quashed.

The Tribunal held that the assessments were barred by limitation as they were completed on March 18, 2016, which is beyond the one-year period from the end of the financial year in which the Section 148 notice was served (i.e., March 31, 2015). Therefore, the assessments were quashed.

The Tribunal held that the reopening of assessment was invalid because the Assessing Officer did not proceed to add the alleged accommodation entries as income in the assessee's hands. The reassessment order's approach was inconsistent with the basis for reopening.

The Tribunal held that the CIT(A) failed to adjudicate the grounds raised by the assessee on the merits of the additions/disallowances. Therefore, the appeals were restored to the file of the CIT(A) for fresh adjudication.

The Tribunal found that the CIT(A) had sustained additions by addressing only grounds on merits, ignoring various legal grounds raised by the assessee. Therefore, the appeals were restored to the CIT(A) for fresh adjudication of all grounds.

The Tribunal held that the CIT(A) failed to adjudicate the grounds raised by the assessee on the merits of the additions/disallowances. Therefore, the appeals were restored to the file of the CIT(A) for fresh adjudication.

The Tribunal held that the CIT(A) failed to adjudicate the grounds raised by the assessee on the merits of the additions/disallowances. Therefore, the appeals were restored to the file of the CIT(A) for fresh adjudication.

The Tribunal held that the notices issued under Section 153C were barred by limitation as they were issued after an inordinate delay. Additionally, the Tribunal found the satisfaction note for initiating proceedings under Section 153C to be defective, as it was borrowed and lacked independent application of mind.

The Tribunal found that the CIT(A) had not adjudicated the grounds on merits. Therefore, the appeals were set aside and restored to the file of the CIT(A) for fresh adjudication on all grounds.

The Tribunal held that the CIT(A) failed to adjudicate the grounds raised by the assessee on the merits of the additions/disallowances. Therefore, the appeals were restored to the file of the CIT(A) for fresh adjudication.

The Tribunal found that the CIT(A) had not adjudicated the grounds on merits. Therefore, the appeals were set aside and restored to the file of the CIT(A) for fresh adjudication on all grounds.

The Tribunal, considering the assessee's land holdings and inheritance of a money lending business, found that a lumpsum addition of Rs. 1,00,000/- would be just and proper. The remaining additions of Rs. 19,00,000/- were deleted.

The Tribunal found that the evidence regarding the date of booking and issuance of the notice was contradictory and did not establish that the notice was issued and handed over to the postal department before the statutory time limit. Therefore, the reassessment proceedings were held to be time-barred.

The Tribunal held that the CIT(A) failed to adjudicate the grounds raised by the assessee on the merits of the additions/disallowances. Therefore, the appeals were restored to the file of the CIT(A) for fresh adjudication.

The Tribunal condoned the delay in filing the appeal before it. It held that technicalities should not impede substantive justice and restored the case to the CIT(A)/NFAC for fresh adjudication on merits.