ITAT Delhi Judgments — April 2026

The Tribunal held that the assessments were barred by limitation as per Section 153(2) of the Act. The assessments should have been completed within one year from the end of the financial year in which the notice under Section 148 was served, i.e., by March 31, 2015.

The Tribunal held that the assessee had provided sufficient documentary evidence, including loan confirmations, bank statements, and NBFC registration, to establish the genuineness of the loan transaction. The AO failed to rebut this evidence or provide contrary material.

The Tribunal held that the seized material did not mention the assessee's name, thus it could not be considered incriminating material against him. Therefore, the addition made by the lower authorities was not sustainable.

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 held that the notice under Section 143(2) was issued beyond the prescribed time limit. Consequently, the reassessment proceedings and the consequential assessment order were vitiated and liable to be quashed.

The Tribunal held that the Assessing Officer's reasons for reopening did not indicate that the assessee had failed to disclose all relevant particulars fully and truly in the original assessment. Relying on the Bombay High Court's decision in Hindustan Lever Ltd vs. R. B. Wadkar, ACIT, the Tribunal quashed the reopening.

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 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 reopening of assessment was invalid because the Assessing Officer failed to dispose of the assessee's objections to the reopening by way of a speaking order, as mandated by Supreme Court decisions. This failure vitiates the entire reassessment proceedings.

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 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.

The Tribunal held that the disallowance under Section 14A cannot exceed the exempt income earned. Relying on judicial precedents, the Tribunal found the Assessing Officer's action to be illegal.

The Tribunal noted that crucial information regarding a forfeited reserve, which formed the basis of the addition, was not submitted before the AO. Therefore, the issue was remitted back to the AO for verification and fresh adjudication.

The Tribunal held that the reassessment proceedings were invalid because the AO failed to demonstrate that the assessee failed to disclose material facts, which is a prerequisite for reopening after four years. The notice issued under Section 148 was quashed.

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 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 observed that the assessee had furnished details to the AO, who denied the expenses without referring to them. The CIT(A)'s orders were also found to be non-speaking. Therefore, the appeals were restored to the AO 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 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 assessee had fulfilled the conditions for Section 54F deduction. It noted that the husband, in a similar situation, was allowed the deduction. The Tribunal found merit in the assessee's grounds of appeal and deleted the disallowance.

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 denying the assessee an opportunity to cross-examine witnesses whose statements formed the basis of the addition is a violation of natural justice. Consequently, the assessment order was deemed bad in law and quashed.

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 additional evidence filed by the assessee, including segmental accounts, was relevant. For complete justice, the issue was remitted back to the Assessing Officer (AO)/Transfer Pricing Officer (TPO) for verification and benchmarking of international transactions.

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 denying the assessee an opportunity to cross-examine witnesses whose statements formed the basis of the addition is a violation of natural justice. Consequently, the assessment order was deemed bad in law and quashed.

The Tribunal held that the filing of Form 67 is a procedural formality and not a mandatory condition to deny FTC. It followed precedents stating that Rule 128 of the IT Rules, 1962, is directory and not mandatory, and distinguished the Supreme Court's ruling in Wipro Ltd. which dealt with exemption provisions.

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 found that the assessee's submissions regarding interest on refunds were not adequately addressed in the first appellate orders. Therefore, the orders were set aside.

The Tribunal found that the assessee's appeal before the CIT(A) was dismissed for delay, but the CIT(A) also made observations on merits, which was not legally permissible. The Tribunal decided to set aside the impugned order.

The Tribunal observed that the assessee had furnished details to the AO, who denied the expenses without referring to them. The CIT(A)'s orders were also found to be non-speaking. Therefore, the appeals were restored to the AO for fresh adjudication.

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 no merit in the PCIT's action. It noted that the PCIT's own order indicated that Section 56(2)(viia) was not applicable and that the outstanding advances could not be disallowed or added under Sections 68, 69, or 41(1).

The Tribunal held that the additions made under Section 143(1) were outside the scope of permissible adjustments under that section, especially for assessment years prior to the Supreme Court's decision in Checkmate Services. Therefore, the additions were deleted.

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 disallowance under Section 14A was unsustainable as the assessee had sufficient own funds exceeding borrowed funds. Regarding gratuity, the addition was restricted to the unpaid balance after considering prepaid amounts.

The Tribunal held that the additions made under Section 143(1) were outside the scope of permissible adjustments under that section, especially for assessment years prior to the Supreme Court's decision in Checkmate Services. Therefore, the additions were deleted.

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 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 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.