ITAT Delhi Judgments — May 2026

The Tribunal upheld the CIT(A)'s decision, finding that assessment years 2013-14 and 2014-15 were outside the block period and that assessments for AY 2019-20 were wrongly initiated under Section 143(3) instead of Section 153C. Furthermore, for other assessment years, the Tribunal found no live nexus between the additions made and the materials seized during the search.

The tribunal held that since the CIT(E) proceeded ex-parte, there might have been communication gaps, especially with the new faceless hearing system. Therefore, in the interest of justice, the appeal was restored to the CIT(E) for fresh adjudication.

The Tribunal upheld the CIT(A)'s decision, finding that the AO failed to conduct independent inquiries and relied solely on information received. The Tribunal noted that the assessee provided sufficient documentary evidence for purchases, sales, and loan repayments through banking channels.

The Tribunal noted that a coordinate bench had previously restored the entire matter to the Assessing Officer for fresh adjudication. Consequently, the penalty in question lost its substratum.

The Tribunal held that the AO cannot reopen the case without credible material to establish escapement of income, and that the addition under Section 68 for purchases already reflected in sales is a double addition. The Tribunal found the proceedings initiated by the AO to be without credible evidence.

The Tribunal restored the issues to the file of the AO for fresh assessment, providing the assessee with an adequate opportunity to present their case. This was done in the interest of justice.

The Tribunal upheld the CIT(A)'s decision, finding that assessment years 2013-14 and 2014-15 were outside the block period and that assessments for AY 2019-20 were wrongly initiated under Section 143(3) instead of Section 153C. Furthermore, for other assessment years, the Tribunal found no live nexus between the additions made and the materials seized during the search.

The Tribunal held that the AO cannot reopen the case without credible material to establish escapement of income, and that the addition under Section 68 for purchases already reflected in sales is a double addition. The Tribunal found the proceedings initiated by the AO to be without credible evidence.

The Tribunal upheld the CIT(A)'s decision, finding that assessment years 2013-14 and 2014-15 were outside the block period and that assessments for AY 2019-20 were wrongly initiated under Section 143(3) instead of Section 153C. Furthermore, for other assessment years, the Tribunal found no live nexus between the additions made and the materials seized during the search.

The Tribunal upheld the CIT(A)'s decision, finding that assessment years 2013-14 and 2014-15 were outside the block period and that assessments for AY 2019-20 were wrongly initiated under Section 143(3) instead of Section 153C. Furthermore, for other assessment years, the Tribunal found no live nexus between the additions made and the materials seized during the search.

The Tribunal upheld the CIT(A)'s decision, finding that assessment years 2013-14 and 2014-15 were outside the block period and that assessments for AY 2019-20 were wrongly initiated under Section 143(3) instead of Section 153C. Furthermore, for other assessment years, the Tribunal found no live nexus between the additions made and the materials seized during the search.

The Tribunal found the NFAC's conclusion to be too harsh, considering the assessee's restricted resources and communication while in custody and immediately after release. Therefore, the Tribunal set aside the NFAC's orders.

The Tribunal upheld the CIT(A)'s decision, finding that assessment years 2013-14 and 2014-15 were outside the block period and that assessments for AY 2019-20 were wrongly initiated under Section 143(3) instead of Section 153C. Furthermore, for other assessment years, the Tribunal found no live nexus between the additions made and the materials seized during the search.

The Tribunal upheld the CIT(A)'s decision, finding that assessment years 2013-14 and 2014-15 were outside the block period and that assessments for AY 2019-20 were wrongly initiated under Section 143(3) instead of Section 153C. Furthermore, for other assessment years, the Tribunal found no live nexus between the additions made and the materials seized during the search.

The Tribunal upheld the CIT(A)'s decision, finding that assessment years 2013-14 and 2014-15 were outside the block period and that assessments for AY 2019-20 were wrongly initiated under Section 143(3) instead of Section 153C. Furthermore, for other assessment years, the Tribunal found no live nexus between the additions made and the materials seized during the search.

The Tribunal found the NFAC's conclusion to be too harsh, considering the assessee's restricted resources and communication while in custody and immediately after release. Therefore, the Tribunal set aside the NFAC's orders.

The Tribunal upheld the CIT(A)'s decision, finding that assessment years 2013-14 and 2014-15 were outside the block period and that assessments for AY 2019-20 were wrongly initiated under Section 143(3) instead of Section 153C. Furthermore, for other assessment years, the Tribunal found no live nexus between the additions made and the materials seized during the search.

The Tribunal held that the approval granted under section 153D was mechanical and lacked proper application of mind by the approving authority. It found that the approval was granted in a formal manner without due consideration of the seized documents and appraisal reports.

The Tribunal held that penalty under Section 271(1)(c) is not leviable when additions are made purely on an estimated basis. Therefore, the penalty levied on estimated additions is unsustainable.

The Tribunal held that the CIT's interpretation of the law was incorrect, citing the Supreme Court's decision in Shital Fibers Limited. Therefore, the AO's original order allowing the deduction was not erroneous or prejudicial to the revenue.

The Tribunal held that assessments framed under Section 153C based on a satisfaction note recorded after April 1, 2021, are bad in law and void-ab-initio. This is due to the insertion of sub-section (3) to Section 153C, which prohibits its application to searches initiated on or after April 1, 2021.

The Tribunal held that the assessment was not sustainable because the Assessing Officer failed to record the requisite satisfaction as mandated by Section 153C of the Act. This failure rendered the assessment invalid.

The Tribunal held that assessments framed under Section 153C based on a satisfaction note recorded after April 1, 2021, are bad in law and void-ab-initio. This is due to the insertion of sub-section (3) to Section 153C, which prohibits its application to searches initiated on or after April 1, 2021.

The Tribunal held that assessments framed under Section 153C based on a satisfaction note recorded after April 1, 2021, are bad in law and void-ab-initio. This is due to the insertion of sub-section (3) to Section 153C, which prohibits its application to searches initiated on or after April 1, 2021.

The Tribunal held that the assessment was not sustainable because the Assessing Officer failed to record the requisite satisfaction as mandated by Section 153C of the Act. This failure rendered the assessment invalid.

The Tribunal held that the assessment was not sustainable because the Assessing Officer failed to record the requisite satisfaction as mandated by Section 153C of the Act. This failure rendered the assessment invalid.

The Tribunal held that the assessment was not sustainable because the Assessing Officer failed to record the requisite satisfaction as mandated by Section 153C of the Act. This failure rendered the assessment invalid.

The Tribunal found the NFAC's conclusion to be too harsh, considering the assessee's restricted resources and communication while in custody and immediately after release. Therefore, the Tribunal set aside the NFAC's orders.

The Tribunal condoned the delay in filing the appeals in the interest of justice. It was held that the assessee did not get a reasonable opportunity of being heard, and therefore, the matter should be remitted back to the CIT(A) for fresh adjudication.

The Tribunal found that the AO did not consider the assessee's submissions and evidence properly. In the interest of justice, the case was remitted back to the AO for a fresh assessment after providing adequate opportunity to the assessee.

The Tribunal held that the approval granted under Section 153D was mechanical and lacked application of mind, thus vitiating the assessment order. The amendment to Section 292BC was found not applicable retrospectively to approvals granted prior to its effective date.

The Tribunal held that the approval granted under section 153D was mechanical and lacked proper application of mind by the approving authority. It found that the approval was granted in a formal manner without due consideration of the seized documents and appraisal reports.

The Tribunal held that the approval granted under Section 153D was mechanical and lacked application of mind, thus vitiating the assessment order. The amendment to Section 292BC was found not applicable retrospectively to approvals granted prior to its effective date.

The Tribunal found the NFAC's conclusion to be too harsh, considering the assessee's restricted resources and communication while in custody and immediately after release. Therefore, the Tribunal set aside the NFAC's orders.

The Tribunal condoned the delay in filing the appeals in the interest of justice. It was held that the assessee did not get a reasonable opportunity of being heard, and therefore, the matter should be remitted back to the CIT(A) for fresh adjudication.

The Tribunal held that penalty under Section 271(1)(c) is not leviable when additions are made purely on an estimated basis. Therefore, the penalty levied on estimated additions is unsustainable.

The Tribunal held that the cash of Rs. 4,05,000, which belonged to the assessee's deceased wife and was declared in her prior income tax return, should not be added to the assessee's income. The Tribunal found the assessee's claim to be correct and not contradicted by any contrary material.

The Tribunal allowed the assessee's appeal, deleting the addition sustained by the CIT(A). It considered the assessee's substantial salary income, family savings, and regular bank withdrawals as sufficient explanation for the cash found.

The Tribunal held that the Income Tax Officer lacked inherent jurisdiction to initiate proceedings under Section 153C as the assessee's returned income exceeded the monetary limits prescribed by CBDT Instruction No. 1/2011. Therefore, the assessment orders were set aside.

The Tribunal held that the lower tax authorities failed to sustain the addition without cogent material. The assessee had discharged the initial onus by showing share purchases online, payments through banking channels, dematerialized shares, and sale proceeds received through banking channels.

The Tribunal held that the satisfaction note recorded under Section 153C was mechanical and bad in law because it was prepared in a composite manner for various assessment years. The Tribunal relied on the Delhi High Court's decision in M/s Saksham Commodities Ltd. Vs. ITO, which mandates that the satisfaction note must clearly indicate the 'bearing' of seized material on the determination of taxable income.

The Tribunal admitted the additional evidence, finding it essential for proper adjudication. The appeal was restored to the Assessing Officer for fresh assessment after considering the new evidence.

The Tribunal held that the Income Tax Officer lacked inherent jurisdiction to initiate proceedings under Section 153C as the assessee's returned income exceeded the monetary limits prescribed by CBDT Instruction No. 1/2011. Therefore, the assessment orders were set aside.

The Tribunal held that the assessment was not sustainable because the Assessing Officer failed to record the requisite satisfaction as mandated by Section 153C of the Act. This failure rendered the assessment invalid.

The Tribunal held that the penalty proceedings were vitiated because the Assessing Officer's show-cause notice under Section 271(1)(c) did not specify the limb under which the penalty was being levied. This procedural defect was considered fatal.

The Tribunal held that the tax effect of the appeal was below the prescribed monetary limit and did not fall under any exceptional clause. Therefore, the appeal was dismissed.

The Tribunal held that the satisfaction note recorded under Section 153C was mechanical and bad in law because it was prepared in a composite manner for various assessment years. The Tribunal relied on the Delhi High Court's decision in M/s Saksham Commodities Ltd. Vs. ITO, which mandates that the satisfaction note must clearly indicate the 'bearing' of seized material on the determination of taxable income.

The Tribunal held that the satisfaction note recorded under Section 153C was mechanical and bad in law because it was prepared in a composite manner for various assessment years. The Tribunal relied on the Delhi High Court's decision in M/s Saksham Commodities Ltd. Vs. ITO, which mandates that the satisfaction note must clearly indicate the 'bearing' of seized material on the determination of taxable income.

The Tribunal held that the notices issued under Section 148 were barred by limitation, as per the Supreme Court's decisions in Ashish Aggarwal and Rajeev Bansal. Consequently, the assumption of jurisdiction by the AO was found to be bad in law.

The Tribunal held that the notices issued under Section 148 were barred by limitation, as per the Supreme Court's decisions in Ashish Aggarwal and Rajeev Bansal. Consequently, the assumption of jurisdiction by the AO was found to be bad in law.