ITAT Delhi Judgments — May 2026

The Tribunal held that for proceedings under Section 153C, incriminating material found during a search must have a bearing on the determination of total income. The Tribunal found that the excel sheet data did not exclusively relate to the assessee and that some transactions pertained to other individuals, making additions unsustainable.

The Tribunal condoned the delay, acknowledging the assessee's lack of familiarity with tax proceedings. It set aside the impugned order and remanded the matter back to the Assessing Officer for a fresh assessment, allowing the assessee an opportunity to present their case.

The Tribunal held that the satisfaction note recorded by the AO for invoking jurisdiction under Section 153C was defective, being common, vague, and mechanical. This failure to meet statutory requirements rendered the assumption of jurisdiction invalid.

The Tribunal held that the assessee had a bona fide belief that his tax obligations were met due to TDS, and all material facts were disclosed. Since the income declared in the Section 148 return was accepted without variation, it was not a case of under-reporting or misrepresentation. Therefore, the penalty under Section 270A was deleted.

The Tribunal condoned the delay in filing the appeal, finding reasonable cause. The orders of the lower authorities were set aside and the matter was remanded to the AO for fresh adjudication.

The Tribunal found that while the CIT(A) provided opportunities, the assessee did not comply. In the interest of justice, the Tribunal set aside the CIT(A)'s orders and remanded the matters back.

The Tribunal found that while the CIT(A) provided opportunities, the assessee did not comply. In the interest of justice, the Tribunal set aside the CIT(A)'s orders and remanded the matters back.

The Tribunal condoned the delay in filing the appeal, citing reasonable and sufficient cause due to internal disputes among trustees and the ill health of the main trustee. The matter was then remanded to the CIT(Exemption) for fresh adjudication.

The Tribunal held that the estimation of profit on work-in-progress was not justified as the assessee consistently recognized revenue based on customer approval and prior years' assessments accepted this method. The cessation of liability and disallowance of provision for expenses were also deleted as the CIT(A) had correctly appreciated the facts.

The Tribunal held that the addition made under Section 143(1) was outside its scope as the issue regarding late deposit of employee's contribution was debatable at the time of processing. The Supreme Court decision in Checkmate Services was rendered later.

The Tribunal held that the satisfaction note recorded by the AO for initiating proceedings under Section 153C was invalid as it was consolidated, lacked year-wise bifurcation of incriminating material, and did not demonstrate application of mind. Consequently, the proceedings and the assessment order were quashed.

The Tribunal held that the satisfaction note recorded by the AO for initiating proceedings under Section 153C was invalid as it was consolidated, lacked year-wise bifurcation of incriminating material, and did not demonstrate application of mind. Consequently, the proceedings and the assessment order were quashed.

The Tribunal held that the satisfaction note recorded by the AO for initiating proceedings under Section 153C was invalid as it was consolidated, lacked year-wise bifurcation of incriminating material, and did not demonstrate application of mind. Consequently, the proceedings and the assessment order were quashed.

The Tribunal held that the satisfaction note recorded by the AO for initiating proceedings under Section 153C was invalid as it was consolidated, lacked year-wise bifurcation of incriminating material, and did not demonstrate application of mind. Consequently, the proceedings and the assessment order were quashed.

The Tribunal held that the notices issued under Section 148 were bad in law as they were issued without the approval of the appropriate authority as required by Section 151. Consequently, the reassessments framed pursuant to these invalid notices were quashed.

The Tribunal held that the notices issued under Section 148 were bad in law as they were issued without the approval of the appropriate authority as required by Section 151. Consequently, the reassessments framed pursuant to these invalid notices were quashed.

The Tribunal held that the addition made under Section 143(1) was outside its scope as the issue regarding late deposit of employee's contribution was debatable at the time of processing. The Supreme Court decision in Checkmate Services was rendered later.

The Tribunal held that the addition made under Section 143(1) was outside its scope as the issue regarding late deposit of employee's contribution was debatable at the time of processing. The Supreme Court decision in Checkmate Services was rendered later.

The Tribunal held that since the additional evidence was vital and the assessee was ex-parte, the ends of justice require restoring the issues to the CIT(A) for fresh consideration.

The Tribunal found that the assessee had sufficient cause for the delay in filing the appeal before the CIT(A). Therefore, the Tribunal directed the CIT(A) to condone the delay and decide the appeal on merits.

The Tribunal noted that the Ld. CIT(A) had dismissed the assessee's appeal on the grounds of delay and the appeal being defective, in violation of the principles of natural justice. The Tribunal found that in the interest of justice, it was expedient to set aside the order of the Ld. CIT(A) dated 29.09.2025. The matter was restored to the file of the Ld. CIT(A) for fresh adjudication in accordance with the law, after affording a fair opportunity of hearing to the assessee. The grounds of appeal were allowed in this manner. The Tribunal did not decide on the substantive issues raised by the assessee regarding the applicability of sections and the merits of the AO's order.

The Tribunal held that since the reopening was made beyond four years from the end of the relevant assessment year, the approval under Section 151(1) ought to have been obtained from the Principal Commissioner of Income Tax (PCIT) and not from the Range Officer. Consequently, the assessment proceedings were not sustainable.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal held that the outstanding amount was a consequence of the Business Transfer Agreement and not an actual loan disbursement. Since the revenue had consistently accepted this position in prior assessment years, the addition for deemed interest was deleted.

The Tribunal held that while the assessee failed to provide complete reconciliation of cash deposits, a lumpsum addition of Rs. 5 lakhs would meet the ends of justice. Additionally, Section 115BBE was held to be applicable only for transactions on or after April 1, 2017.

The Tribunal held that 'protective' additions are made to safeguard the Revenue's interest and should not be revived if substantive additions have already been confirmed in another person's hands. The appeal was accordingly rejected.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal held that reopening the assessment beyond three years required approval from the PCCIT or CCIT, not just the PCIT. Since the approval was not from the competent authority, the notice u/s 148 was defective.

The Tribunal held that the valuation report filed by the assessee as additional evidence before the CIT(A) should be admitted. The matter was restored to the AO for re-examination of the cost of acquisition in light of the valuation report.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal restored the matter to the Assessing Officer for a fresh assessment. This was done in the interest of justice to provide the assessee with a reasonable opportunity to present their case.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found that the NFAC passed ex-parte orders without independent findings on merits. Therefore, in the interest of justice, the appeals were restored to the NFAC for de novo adjudication.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal found no substance in the Revenue's grounds of appeal as the CIT(A) had correctly followed a coordinate bench decision in the assessee's own case. The additions were consequential to the cancellation of registration, which was already set aside.

The Tribunal held that CSR expenses are not allowable as deduction under Section 80G. However, it allowed the claim for CSR expenses as it was raised before the CIT(A) and the assessment was processed under Section 143(1). The addition of profit on sale of depreciable asset was also held unsustainable as Section 50 was not applicable.

The Tribunal held that CSR expenses are not allowable as deduction under Section 80G. However, it allowed the claim for CSR expenses as it was raised before the CIT(A) and the assessment was processed under Section 143(1). The addition of profit on sale of depreciable asset was also held unsustainable as Section 50 was not applicable.

The Tribunal found that the assessees claimed to have filed replies and sought adjournments due to counsel's busy schedule. The Tribunal granted a fresh opportunity to the assessees to present their cases before the CIT(E) with supporting evidence.

The Tribunal upheld the denial of exemption for agricultural income. It found that the assessee did not perform basic agricultural operations like tilling and sowing, and the income was derived from procurement of seeds rather than from the land itself.